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EBA RISK REDUCTION PACKAGE ROADMAPS
EBA TASKS ARISING FROM CRD 5 – CRR 2 – BRRD 2
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Contents
List of tables 12
List of figures 12
Introduction 13
Background and summary of plans 13
Clarity on EBA regulatory mandates and main areas of work 13
The Risk Reduction Measures Package and its detailed Roadmaps 14
1. Roadmap for the delivery of the EBA mandates on governance and remuneration 23
1.1 Introduction and background 23
Remuneration requirements under CRD 5 23 Governance requirements under CRD 5 24
1.2 The EBA’s policy strategy on governance and remuneration 25
1.3 Expected timeline for deliverables 25
2. Roadmap for the delivery of the EBA mandates on large exposures 28
2.1 Introduction and background 28
2.2 The EBA’s policy strategy on large exposures deliverables 29
Regulatory technical standards on the determination of the exposures arising from derivatives contracts and credit derivatives underlying a debt or equity instrument 30 Guidelines specifying the conditions for the substitution approach in respect of exposures collateralised by the market value of recognised collateral (‘tri-party transactions’) 30 Implementing technical standards on supervisory reporting 30 Guidelines specifying the exceptional circumstances under which the large exposure limits may be breached and corrective measures 31 Regulatory technical standards on connected clients 31 Regulatory technical standards specifying the criteria for the identification of shadow banking entities 31 Report on the quantitative impact of the removal of, or the setting of a limit to, some exemptions to the large exposures framework 32
2.3 Expected timeline for deliverables 33
3. Roadmap for the delivery of the EBA mandates on Pillar 2 34
3.1 Introduction and background 34
3.2 The EBA’s policy strategy on Pillar 2 deliverables 36
Changes to the Pillar 2 framework and mandates from CRD 5 36 Proportionality 37 Sustainable finance 38 Assessment of ML/TF risks from a prudential perspective 38 Microprudential perspective of Pillar 2 39 Pillar 2 capital add-ons and Pillar 2 guidance 40 Framework for interest rate risk in the non-trading book (IRRBB) 41
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Other changes 43
3.3 Expected timeline for deliverables 43
4. Roadmap for the delivery of the EBA mandates on resolution 45
4.1 Introduction 45
4.2 The EBA’s policy strategy on resolution 45
4.2.1 Mandates related to MREL eligible liabilities instruments 46 4.2.2 Mandates related to MREL reporting and monitoring 47 4.2.3 Mandates related to setting MREL 48 4.2.4 Mandates related to contractual terms on bail-in and resolution stay powers 49
4.3 Expected timeline for deliverables 49
5. Roadmap on the delivery of the EBA mandates on Pillar 3 disclosures 52
5.1 Introduction and background 52
5.2 The EBA’s policy strategy on institutions’ disclosures 54
Proportionality in Pillar 3 disclosures 56 The EBA as the EU Pillar 3 disclosure hub 56
5.3 Expected timeline for deliverables 57
6. Roadmap for the delivery of the EBA mandates on supervisory reporting 61
6.1 Introduction and background 61
General overview of EU supervisory reporting framework 63 EBA regulatory mandates on reporting 64
New banking regulatory package 64 Regulation on minimum coverage of non-performing exposures 64 Investment firms’ regulatory package 64
6.2 The EBA’s policy strategy on supervisory reporting 65
6.2.1 Upcoming changes to the EBA reporting framework 66 Prudential and financial reporting 67 Reporting changes resulting from CRR 2 and the Backstop Regulation 67 Other amendments 69 Supervisory benchmarking 70 Funding plans 70 Resolution reporting 70 Reporting by investment firms 71 6.2.2 The EBA’s work to increase the proportionality and enhance the efficiency of the reporting framework 72 Proportionality in reporting requirements 72 EBA report on the costs and benefits of reporting requirements 73 EBA feasibility report on integrated reporting 73 Integration of Pillar 3 disclosure requirements into supervisory reporting 75 Reporting compliance tool 76 Changes to the reporting framework and implementation timelines 76 Validation rule management 77
6.3 Expected timeline for deliverables 77
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List of tables
Table 1: Timetable of mandates related to remuneration and governance ...............................26
Table 2: Timetable of mandates related to large exposures....................................................33
Table 3: Timeline of mandates related to Pillar 2 deliverables.................................................43
Table 6: Timetable of mandates related to resolution ...........................................................50
Table 4: Timetable of mandates related to disclosure ............................................................58
Table 5: Timetable of mandates related to supervisory reporting ............................................77
List of figures
Figure 5: Overview of the EBA’s work on reporting ...............................................................63
Figure 6: Integration of disclosure requirements with supervisory reporting.............................76
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Introduction
Background and summary of plans
1. The formal legislative texts related to the Risk Reduction Measures package have been adopted
by the Council of the EU and the European Parliament on 20 May 2019 and published in the
Official Journal (OJ) on 7 June 20191. The Package amends rules on capital requirements under
the Capital Requirements Directive 5 (CRD 5) and the Capital Requirements Regulation 2 (CRR
2) as well as resolution under the revised Bank Recovery and Resolution Directive (BRRD 2) and
the Single Resolution Mechanism Regulation. The Package includes numerous new mandates
for the EBA, being regulatory or implementing technical standards (RTS/ITS), guidelines (GLs) or
reports. In addition, the new investment firms regime, as established under the IFD-IFR texts, is
intended to be published in the OJ by November 2019.
2. As follow-up to the EBA’s Roadmap on Market Risk2 this set of roadmaps outlines the EBA
approach and timelines to deliver on the mandates given to the EBA especially in the areas of
Pillar 2, governance and remuneration, Large Exposures, resolution as well as reporting and
disclosure. Moreover and in view of the co-legislators’ close attention paid to money laundering
and sustainable finance, the EBA will present two more detailed Action Plans on these areas,
which will outline the policy stance and sequencing of mandates in the respective areas.
Clarity on EBA regulatory mandates and main areas of work
General sequencing
3. The Risk Reduction Package gives rise to around 100 new mandates for the EBA under CRD 5-
CRR 2 and BRRD 2. Most of the mandates are of regulatory essence to complete and update the
Single Rule Book. In addition to that, co-legislators acknowledged the important role of the EBA
in monitoring practices. Hence, around 30 reports or sets of monitoring actions are due to
support the effective and consistent implementation of the Single Rule Book as well as its
supervisory convergence in practice.
4. The EBA is above all paying attention to the delivery dates as set by the co-legislators in the
prioritisation of its work. Such deadlines drive the sequencing of the work calendar in first
instance. There are however contingencies that may limit the ability of the EBA to deliver all
mandates on time.
Transparency on Delays
5. Out of all mandates attributed to the EBA, a small number of mandates prescribe a deadline of
6-9 months after entry into force of CRD 5 and CRR 2. Timely delivery will remain very
1 OJ L 62, 7.6.2019: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2019:150:FULL&from=END. 2 EBA Roadmap for the new Market and Counterparty Credit Risk approaches . 27 June 2019: https://eba.europa.eu/file/104484/download?token=ZTdEDC-o.
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challenging for most of them as stakeholders need to be consulted properly in order to collect
evidence, consult and prepare robust adhesion to the future standards across the EU. In
contrast to the area of market risk where consultation papers could be issued before the Official
Journal (OJ) publication of CRR 2, almost all mandates with 6-9 months deadlines risk to be
delayed by 3 up to approximately 9 months from the deadline set in the legislative texts.3
6. For mandates with deadlines within 1-year or more, the EBA will strive to deliver on time for its
submission to the European Commission. Some limited delays are however anticipated in the
areas of Large Exposures, IRRBB and MREL or Bail-in execution due to their complexity and/or
contingency to substantive progress in other areas such as Pillar 2 and internal MREL. Likewise,
some mandates on reporting may also be delayed as any calibration of requirements is
contingent on an agreement on the policy side. The delay can also be influenced by the
sequencing of the work in the event that the content needs to be aligned to other EBA work that
is still in progress, such as for guidelines on cooperation between authorities. The detailed
Roadmaps support the explanatory communication on the actual sequencing and possible
delays.
The Risk Reduction Measures Package and its detailed Roadmaps
7. The detailed Roadmaps provide clarity on the early understanding of the mandates and changes
in legislation, the timeline for consultation and submission. All roadmaps outline transparently
expected plans and sometimes delays on specific EBA mandates as it could occur. The detailed
Roadmaps cover the areas of Governance and Remuneration, Large Exposures, Pillar2,
Reporting and Disclosure as well as Resolution. All detailed roadmaps outline as well how
proportionality as key consideration in the overhaul of CRR 2-CRD 5 in the mandates will be
addressed.
8. In the area of governance, the EBA will help optimising the existing framework with a particular
primary emphasis on the finalisation of the remuneration deliverables. Especially for the work
on identified staff, the prior EBA peer review will inform the way forward. Through the
advancement on these mandates it will be key to closely cooperate with ESMA and to be
conscious on the alignment between the CRD 5 and IFD.
9. For Large Exposures, the Roadmap outlines the EBA’s planned work in three staggered phases
where priority would be to complete the framework where currently no EBA work exists such
as the determination of exposures arising from derivatives. Only in a second stage and in view
of existing EBA Guidelines, the EBA would address the identification of connected clients and
shadow banking entities as more research guiding the analysis will be needed.
10. The roadmap on the EBA’s Pillar 2 work outlines the two phases to work on the changes in the
framework coming from CRD 5 and links them back to the initial EBA Roadmap of April 2017.
The EBA will look into making the Pillar 2 framework fit for purpose in view of ongoing and new
challenges. Proportionality will be strengthened, and the AML/CTF dimension will be clarified
together with Pillar 2 capital add-ons. Both phases offer the opportunity to enhance the
3 Cf. Annex 1 for a comprehensive list of EBA mandates from CRD 5/CRR 2, BRRD 2, IFR-IFD with deadlines 6-9 months.
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common supervisory risk taxonomy.The work on IRRBB will be sequenced in view of the recent
application of the EBA’s guidelines, and the consideration to sustainable finance will be included
after the issuance of the related report.
11. The need for an efficient reporting framework with enhanced proportionality underlies the
considerations in the detailed reporting roadmap. In view of the short deadlines foreseen, the
roadmap provides an overview on immediate but also medium-term work. Proportionality will
be a key element throughout the work on all mandates and deliverables.
12. When it comes to disclosure, the mandates on Pillar 3 disclosures and the mapping of all the
quantitative templates with supervisory reporting data point by data point will inform the
potential role of the EBA to become the EU-wide Pillar 3 hub following the completion of EUCLID
project.
13. The Resolution Roadmap outlines the EBA’s work in facilitating effective resolution planning and
preparedness and smooth execution of resolution action. The mandates aime to complete the
framework concerning eligible liability instruments and the setting of MREL, ensure an
harmonised framework for reporting and disclosure of MREL and foresee an appropriate role of
the EBA in monitoring MREL implementation and consistency across Europe.
14. In addition to the detailed roadmaps, the Risk Reduction Measures Package is due to secure a
sound level playing field in the Single Market and it confers on the EBA a number of new
mandates in relation to market access, authorisations and third country branches4. To that end,
the EBA will put forward guidelines, which will help harmonising the authorisation process and
practices. The link between prudential and AML/CFT supervision will be further strengthened by
updating existing RTS/ITS.
15. Finally, the EBA will assess the level playing field within the EU concerning third country
branches. The reports mandated to the EBA will look in depth into the major differences, which
exist at the entry point of the authorisation process that subsequently informs the conditions
for operations. The EBA will further analyse attentively the lack of transparency as regards the
imposition of requirements on incoming branches and variations in the nature of the
requirements imposed by host jurisdictions.
4Directive (EU) 2019/878 of 20 May 2019 amending Directive 2013/36/EU: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2019.150.01.0253.01.ENG&toc=OJ%3AL%3A2019%3A150%3ATOC
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Infographics
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1. Roadmap for the delivery of the EBA mandates on governance and remuneration
1.1 Introduction and background
16. Directive 2019/878/EU (CRD 5), adopted on 20 May 2019, amends Directive 2013/36/EU (CRD,
the Capital Requirements Directive) as regards, among other things, governance and
remuneration. In particular, several CRD remuneration provisions were amended to take into
account the European Commission report of 28 July 2016 on the assessment of the
remuneration requirements5.
Remuneration requirements under CRD 5
17. The main changes introduced by CRD 5 and the revised Capital Requirements Regulation (CRR 2)
regarding remuneration requirements are related to:
- the scope of application, as the CRD now addresses credit institutions and significant
investment firms (category 2 and category 3 investment firms are not subject to the CRD) as
well as holding companies6;
- the categorisation of staff considered to have a material impact on an institution’s risk
profile has been clarified, and some of the qualitative criteria are now specified directly in
the legislative text;
- the possibility for listed institutions to award share-linked instruments;
- the minimum deferral period, which has increased from 3 to 4 years and, for members of
the management body and senior management in ‘significant’ institutions, to 5 years;
5 In addition to CRD 5, the European Commission has proposed a specific new prudential framework for investment firms
(Investment Firms Directive, IFD) that are not systemic by virtue of their size or interconnectedness with other financial
and economic actors. The new investment firms ’ regime has been adopted by the co-legislators and is due to be published
in the Official Journal of the European Union soon. Systemic investment firms should remain subject to the existing
prudential framework under CRD/CRR. For the other categories of investment firms, in particular Class 2 firms, it is a
requirement that they should have sound governance arrangements and comply with remun eration requirements set
out in the IFD. Most of the requirements envisaged under CRD have been replicated in the IFD taking into account the
size, nature and complexity of investment firms’ activities. The IFD mandates assigned to the EBA in the areas of
governance and remunerations broadly mirror the CRD mandates on the same areas. The EBA will work on the CRD and
IFD mandates in parallel in order to ensure cross-sectoral consistency. The work of the EBA mandates stemming from the
new investment firms regime texts will be soon available in a dedicated roadmap.
6 CRR 2 provides definitions for the terms ‘group’, ‘small and non-complex institution’ and ‘large institution’ that need to be reflected in the EBA regulatory products.
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- the introduction of a waiver to better account for the proportionality principle; in particular
it is now allowed to derogate from the requirements to pay out variable remuneration in
instruments and to have retention and deferral arrangements:
o where the institution is not a ‘large institution’ and the institution’s average asset
value on an individual basis is equal to or less than EUR 5 billion over the 4 years
preceding the current financial year (although a Member State may lower this
threshold or increase it up to EUR 15 billion); and/or
o where the relevant staff member’s variable remuneration does not exceed
EUR 50 000 and does not represent more than one third of their total annual
remuneration, although a Member State may decide this exemption will not apply;
the EBA has a mandate to issue guidelines to further specify those derogations.
- the group application envisaged under Article 109 of the CRD, which has been adjusted; the
remuneration requirements will not apply on a consolidated basis to undertakings within
the scope of consolidation when they are subject to other specific EU remuneration
requirements (i.e. undertakings for the collective investment in transferable securities,
UCITS, and alternative investment funds are excluded);
- gender neutrality of remuneration, which will be further specified through EBA guidelines;
this mandate is then followed by a review, benchmarking and reporting requirement for the
EBA;
- the disclosure requirements, which have been clarified and adjusted (e.g. with respect to
gender-neutral pay).
Governance requirements under CRD 5
18. The main changes relevant for governance requirements are related to risk management and
the management body’s involvement in the risk management oversight. In addition:
- the scope of application, since CRD is addressed now to credit institutions and significant
investment firms (category 2 and category 3 investment firms are not subject to the CRD);
- the clear reference in Article 91 to the primary responsibility of financial holding companies
and mixed financial holding companies, alongside institutions, for ensuring that members
of the management board are fit and proper;
- the development of the regime on loans to members of the management body and their
related parties;
- the clarification that money laundering and financing of terrorism risk is part of the
supervisory review and evaluation process and therefore of the sound governance
arrangements and that this can be taken into account in the fit and proper assessment;
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- the consistent application of the power of competent authorities to remove members of
the management body, in line with Article 91 as amended.
- the clarification that being a member of affiliated companies or affiliated entities does not
in itself constitute an obstacle to acting with independence of mind;
- the definition of group (including the application of the arrangements, processes and
mechanism to offshore financial centres) and the inclusion of holding companies (which will
need to be reflected throughout existing guidelines, e.g. guidelines on the counting of
directorships).
1.2 The EBA’s policy strategy on governance and remuneration
19. The key objectives of the EBA’s strategy in terms of policy in the areas of governance and
remuneration are outlined below:
a. Optimise the existing framework under the CRD, with amendments to existing EBA
regulatory products limited to changes introduced by CRD 5 and clarify them where
necessary and relevant to avoid legal uncertainty for both competent authorities
and institutions (e.g. by including existing answers from the Q&Atool). This
approach is deemed to alleviate the burden for institutions and limit their
implementation costs. Consideration should also be given to potential future
changes and general expectations around governance and conduct in areas such as
anti-money laundering and combating the financing of terrorism (AML/CFT) and
sustainable finance and environmental, social and governance factors7.
b. Ensure, where possible, cross-sectoral consistency between the governance and
remuneration framework under CRD and IFD, also taking into account the
requirements set out within the Alternative Investment Fund Managers Directive
and UCITS Directive as mandated within the IFD and related ESMA Guidelines.
c. Ensure a harmonised and consistent approach within the EU regarding the
application of the proportionality for both remuneration and governance under the
CRD, by providing guidelines in these areas.
20. In line with the above, the EBA has several mandates to draft regulatory technical standards
(RTS) and guidelines in the areas of governance and remuneration with specific deadlines to be
met.
1.3 Expected timeline for deliverables
21. The table below outlines all the EBA remuneration and governance mandates together with the
deadlines envisaged under CRD 5 and the planned timelines.
7 The EBA will publish a dedicated roadmap on this topic soon.
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22. In its approach to prioritisation, the EBA has started from the timelines set out for each mandate
by the co-legislators. However, those timelines are often very ambitious and they may not allow
the EBA sufficient time for effective and practical delivery of all products for a variety of reasons,
including the need to agree on robust grounds across the EBA membership, relying on adequate
information and a common understanding of what are good policies to implement, as well as
the need to properly consult an adequate range of stakeholders. Considering the time
constraints, in order to ensure that proper internal governance and public consultation
processes are followed, it is the EBA’s assessment that in general it will not be possible to deliver
in less than 9-12 months.
23. In particular, the EBA will not be able to deliver the RTS on remuneration within the deadline
provided by the legislation. The existing RTS on identified staff is being reviewed first with a view
to amending it in line with the limited changes introduced by the legislation. The review of the
RTS on identified staff will also be informed by the peer review report on the RTS on identified
staff, which is being concluded. The draft RTS should be published for consultation by the end
of 2019. The submission of the final draft RTS to the European Commission is planned for June
2020.
24. The work on the CRD guidelines on sound remuneration policies started in September 2019.
Clarifications for the application of the proportionality principle will be provided to support a
consistent EU approach.
25. The existing guidelines on fit and proper and internal governance will also be amended, having
regard to the changes made to the remuneration and governance requirements, namely the
scope of addressees, the regime on loans to members of the management body and their
related parties, the independence criteria and the link with AML/CFT and the power to remove
members of the management body. Existing category 1 and category 2 Q&A will be taken into
account when amending the guidelines.
26. The work on the guidelines on data collection of high earners and on benchmarking of
remuneration practices is more likely to start around the end of 2020.
Table 1: Timetable of mandates related to remuneration and governance
Mandate Original deadline
Proposed deadline
Mandates related to remuneration
Art. 94(2) of the CRD: RTS on identified staff 28 December 2019
June 2020
Art. 74(3) of the CRD: Guidelines on sound remuneration policies and proportionally gender-neutral pay
No deadline First quarter 2021
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Art. 75(3) of the CRD: Guidelines on data collection of high earners
No deadline Last quarter 2021
Art. 75(2) of the CRD: Guidelines on benchmarking of remuneration practices
No deadline Last quarter 2021
Mandates related to governance
Art. 74(3) of the CRD: Guidelines on internal governance No deadline First quarter 2021
Art. 91(12) of the CRD: Guidelines on the assessment of the suitability of the members of the Management body and key function holders
No deadline First quarter 2021
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2. Roadmap for the delivery of the EBA mandates on large exposures
2.1 Introduction and background
27. The Regulation amending the Capital Requirements Regulation (CRR) entered into force on
27 June and will apply from 28 June 2021 onwards with the exception of some provisions (not
pertaining to large exposures), as set out in Article 3(2) of the amending regulation.8
28. This roadmap provides a general overview of the main changes included in the large exposures
regime (Part 4 of the amended CRR) as well as an overview of the deliverables on which the EBA
plans to work in the coming months and years. It also aims to prioritise these deliverables and
to provide a timeline for their completion.
29. In October 2016, the EBA issued an opinion in response to a Commission call for advice, setting
out its views on the review of the large exposure regime.9 In that opinion, the EBA called on the
EU institutions to introduce some amendments to (a) align the CRR with the Basel standard on
large exposures, (b) remove some exemptions and (c) improve some technical details.
30. The amended CRR has retained some of the elements of the EBA’s opinion. These amendments
ensure greater alignment with the Basel standard (LEX).10 For instance, the capital basis on which
large exposures and large exposure limits are calculated will be restricted to Tier 1 capital; and
a tighter limit on exposures between global systemically important institutions (G-SIIs) (15% of
Tier 1 capital) was introduced.
31. With regard to the treatment of institutions’ exposures to ‘shadow banking entities’, the EBA
offered to submit a report to the Commission, after an observation period on the effectiveness
of the existing guidelines, including proposals, if appropriate, on which aspects could be
transformed into a regulation to achieve a higher degree of harmonisation. In addition, the EBA’s
opinion suggested a new mandate to develop and harmonise the treatment of breaches of the
large exposures regime; recommended including in the CRR the requirement to report in COREP
exposures with a value ≥ EUR 300 million (currently reported in FINREP); and gave a new
8 Regulation (EU) 2019/876 of the European Parliament and of the Council of 20 May 2019 amending Regulation (EU) No 575/2013 as regards the leverage ratio, the net stable funding ratio, requirements for own funds and eligi ble liabilities, counterparty credit risk, market risk, exposures to central counterparties, exposures to collective investment undertakings, large exposures, reporting and disclosure requirements, and Regulation (EU) No 648/2012. OJ L 150, 7.6.2019, p. 1-225 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019R0876).
9 The EBA’s response to the European Commission’s call for advice, EBA-OP-2016-17 of 24 October 2016 (https://eba.europa.eu/documents/10180/1632518/EBA+report+on+the+review+of+the+large+exposures+regime +%28EBA-Op-2016-17%29.pdf). 10 BCBS, Supervisory framework for measuring and controlling large exposures (https://www.bis.org/publ/bcbs283.pdf).
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mandate to develop technical standards in the area of connected clients (currently in
guidelines). These elements were included in the amended CRR.
32. The EBA also provided its views on five discretionary exemptions included in the Commission’s
call for advice, namely those currently in points (d), (e), (f), (j) and (k) of Article 400(2) and 493(3)
of the CRR.
33. The following changes (date of application: 28 June 2021) and EBA mandates were included in
the amended CRR:
a. definition of connected clients (Art. 4(1)(39) and Art. 4(4) of the CRR) — Regulatory
Technical Standards (RTS) mandate (by 28 June 2020);
b. calculation of exposures in the trading book and offsetting of positions (Art. 390(9) of
the CRR) — RTS mandate (by 28 March 2020);
c. definition of capital basis (Art. 392 of the CRR) — Tier 1 instead of eligible capital;
d. reporting of exposures of a value ≥ EUR 300 million but less than 10% of the
institutions’ Tier 1 capital (Art. 394(1) of the CRR) — already part of Commission
implementing Regulation (EU) No 680/2014 on supervisory reporting;
e. definition of shadow banking entities (Art. 394(4) of the CRR) — RTS mandate (by
28 June 2020);
f. removal of reporting of maturity buckets (Art. 394(2) of the CRR) — change of
reporting Regulation 680/2014 necessary;
g. limits to exposures between G-SIIs (Art. 395(1) of the CRR) — the limit must be
observed within one year of identification as G-SII;
h. guidance on restoring compliance with large exposure limits (Art. 396(3) of the CRR)
— guidelines mandate (no deadline);
i. changes to the use of credit risk mitigation (CRM) techniques (Art. 399 of the CRR);
j. modifications to the exemptions regime (Art. 400 of the CRR)
k. possibility for national law to prevent institutions from reducing the value of an
exposure that is fully secured by residential or commercial property (Art. 402(1) and
(2) of the CRR);
l. mandatory substitution approach (Art. 403 of the CRR);
m. guidance on application of tri-party treatment (Art. 403(4) of the CRR) — guidelines
mandate (by 31 December 2019);
n. update of reporting Implementing Technical Standards (ITS) to reflect CRR 2 changes
(Art. 430(7) of the CRR);
o. EBA monitoring of use of exemptions (Art. 507(1) of the CRR) — report mandate (by
28 June 2021);
p. Commission report on application of derogations regarding SFTs (Art. 507(2) of the
CRR, by 31 December 2023).
2.2 The EBA’s policy strategy on large exposures deliverables
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34. The section below details the content of the new EBA mandates and provides preliminary
considerations for the EBA’s intentions on the way forward on these mandates. In general, the
EBA expects to consider a period of not less than 12 months necessary to complete an assigned
mandate in order to provide high-quality work, noting the need to conduct full consultations
with stakeholders.
Regulatory technical standards on the determination of the exposures arising from derivatives contracts and credit derivatives underlying a debt or equity instrument
35. Article 390(9) of the CRR mandates the EBA to submit to the Commission by 28 March 2020
draft RTS to specify, for the purpose of paragraph 5, how to determine the exposures arising
from derivative contracts listed in Annex II and credit derivative contracts, in which the contract
was not directly entered into with a client but the underlying debt or equity instrument was
issued by that client for inclusion in the exposures to the client.
36. The work related to this mandate has started.
Guidelines specifying the conditions for the substitution approach in respect of exposures collateralised by the market value of recognised collateral ( ‘tri-party transactions’)
37. Article 403(4) of the CRR requires the EBA to issue, by 31 December 2019, guidelines specifying
the conditions for the application of the treatment referred to in paragraph 3, including the
conditions and frequency for determining, monitoring and revising the limits referred to in
point (b) of that paragraph. Paragraph 3 provides for the possibility that institutions replace the
total amount of the institution’s exposure to a collateral issuer due to tri-party repurchase
agreements facilitated by a tri-party agent with the full amount of the limits that the institution
has instructed the tri-party agent to apply to the securities issued by the collateral issuer.
38. The work related to this mandate has started.
Implementing technical standards on supervisory reporting
39. Article 430(7) of the CRR mandates the EBA to develop draft ITS to specify ‘the uniform reporting
formats and templates, the instructions and methodology on how to use those templates, the
frequency and dates of reporting, the definitions and the IT solutions for the reporting referred
to in paragraphs 1 to 4. Any new reporting requirements set out in such implementing technical
standards shall not be applicable earlier than six months from the date of their entry into force.’
40. The draft ITS must be submitted to the Commission by June 2020. The reporting obligations in
terms of large exposures are set out in Article 394 of the CRR.
41. Commission Implementing Regulation (EU) No 680/2014 laying down ITS with regard to
supervisory reporting of institutions is the current legal instrument providing for supervisory
reporting. Annexes VIII and IX deal in particular with large exposures. It will be necessary to
assess the changes introduced in the amended CRR and reflect them in the draft ITS.
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42. The work under the draft ITS has already started and consultations should take place before the
end of 2019.
Guidelines specifying the exceptional circumstances under which the large exposure limits may be breached and corrective measures
43. Under the mandate of Article 396(3) of the CRR, the EBA is to issue guidelines specifying how
competent authorities should deal with breaches of limits, in particular how they may determine
(a) the exceptional cases under which exposures may exceed the large exposure limits, (b) the
time considered appropriate for returning to compliance with the limits, and (c) the measures
to be taken to ensure the institution’s timely return to compliance.
44. The CRR does not contain a specific timeline to deliver this mandate. As these guidelines can
become an important tool for supervisors and there is a need to harmonise this area in line with
the EBA’s opinion, it is suggested that they be published by December 2021.
Regulatory technical standards on connected clients
45. Article 4(4) of the CRR requires the EBA to submit to the Commission, by June 2020, draft RTS
specifying in which circumstances the conditions set out in point (39) are met. Point (39),
containing the definition of a group of connected clients, was only slightly modified (to include
a clarification regarding exposures to CCPs).
46. It must be recalled that the EBA adopted own-initiative guidelines on connected clients under
Article 4(1)(39) of the CRR.11 These guidelines have applied since 1 January 2019 to competent
authorities and financial institutions. They elaborate on the concepts of control and economic
dependency, which are the backbone of the definition of a group of connected clients. Both
concepts remain unaltered in the amended CRR.
47. Given the recent application date of those guidelines, for which institutions and competent
authorities have to put in place relevant systems and processes to give effect to them, it would
be beneficial to gain sufficient experience of their application and discuss with stakeholders
possible amendments before their integration into the draft RTS. For those reasons, their
submission could be delayed by 2.5 years, i.e. until December 2022.
Regulatory technical standards specifying the criteria for the identification of shadow banking entities
48. Under Article 394(4) of the CRR, the EBA is mandated to submit to the Commission by 28 June
2020 draft RTS to specify the criteria for the identification of shadow banking entities.
Paragraph 2 concerns the reporting by institutions to competent authorities of their 10 largest
exposures to institutions on a consolidated basis as well as their 10 largest exposures to shadow
11 Final report on Guidelines on connected clients under Article 4(1)(39) of Regulation (EU) No 575/2013 of 14 November 2017, EBA/GL/2017/15 (https://eba.europa.eu/documents/10180/2025808/Final+Guidelines+on+connected+clients+%28EBA-GL-2017-15%29.pdf/a77be1e9-7564-47d2-a9d1-b7da98220352).
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banking entities that carry out banking activities outside the regulatory framework on a
consolidated basis, including large exposures exempt from the application of Article 395(1).
49. Pursuant to the mandate under the current Article 395(2) of the CRR, the EBA published in 2015
guidelines on limits on exposures to shadow banking entities that carry out banking activities
outside the regulatory framework under Article 395(2) of Regulation (EU) No 575/2013.12 The
guidelines have applied since 1 January 2017.
50. It will take some time to research and assess developments at international level in the area of
shadow banking as well as to coordinate with other bodies that are working on the matter with
a view to ensuring that the draft RTS reflect on all these developments. In the meantime, the
current guidelines remain applicable and provide a definition of shadow banking entities under
which institutions will continue to meet their obligations to report exposures. It is also the EBA’s
view that an observation period on the effectiveness of the existing guidelines could be
beneficial before developing draft RTS. The EBA will also need to consider if a data collection,
similar to that conducted in 2015, needs to be carried out again.13
51. Therefore, it is suggested that the submission of the draft RTS be postponed by 18 months, i.e.
until December 2021.
Report on the quantitative impact of the removal of, or the setting of a limit to, some exemptions to the large exposures framework
52. Under Article 507(1) of the CRR, the EBA is mandated to monitor the use of the exemptions set
out in:
Article 390(6)(b) on the settlement of the purchase or sale of securities;
Article 400(1)(f) to (m) including, inter alia, exposures to counterparties with a 0% risk
weighting, secured asset items and other exposures, clearing members’ trade exposures
and default fund contributions to qualified central counterparties, etc.; and
Article 400(2)(a), (c) to (g), (i), (j) and (k), which include covered bonds, intra-group
transactions, claims on central banks in the form of required minimum reserves held at
those central banks and denominated in their national currencies, exposures in the form of
a collateral or a guarantee for residential loans, provided by an eligible protection provider,
etc.
53. By June 2021, the EBA is to submit a report to the Commission assessing the quantitative impact
that the removal of those exemptions or the setting of a limit on their use would have. For each
exemption, the report should assess:
a) the number of large exposures exempted in each Member State;
12 Guidelines on limits on exposures to shadow banking entities which carry out banking activities outside a regulated framework under Article 395(2) of Regulation (EU) No 575/2013 of 14 December 2015, EBA/GL/2015/20 (https://eba.europa.eu/sites/default/documents/files/documents/10180/1310259/ca01acf7 -46c9-49d1-9f1a-92f3531df1cf/EBA-GL-2015-20%20GL%20on%20Shadow%20Banking%20Entities_EN.pdf ).
13 See Report on institutions’ exposures to ‘shadow banking entities’, 2015 data collection (https://eba.europa.eu/documents/10180/950548/Report+on+institutions+exposures+to+s hadow+banking+entities.pdf).
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b) the number of institutions that make use of the exemption in each Member State; and
c) the aggregate amount of exposures exempted in each Member State.
54. There will be a need to perform an exhaustive review of the use of the exemptions in order to
determine the impact of their possible removal. This report could be submitted to the
Commission 6 months later than the set deadline, i.e. by December 2021. This additional time
would be needed to run a data collection as well as to involve competent authorities and
institutions in such a process.
2.3 Expected timeline for deliverables
55. Based on the above, the tentative timeline for EBA deliverables is detailed in the following table.
As explained before, the EBA normally considers a period of not less than 12 months to complete
an assigned mandate.
56. In view of the deadlines set out in the amended CRR, it is suggested that a staggered approach
be taken, whereby the mandates would be delivered in three phases according to their priority,
based on the rationale provided in the previous section. The proposed revised deadlines are
meant to be the time when the work will be delivered at the latest. In addition, the work on
some of the deliverables will start in the coming months (i.e. for the mandate on the possible
breaches of large exposure limits).
Table 2: Timetable of mandates related to large exposures
Mandate Original deadline
Proposed deadline
Phase 1
Art. 390(9) of the CRR: draft RTS on the determination of the exposures arising from derivatives contracts and credit derivatives underlying a debt or equity instrument
March 2020 December 2020
Art. 403(4) of the CRR: Guidelines specifying the conditions for the substitution approach in respect of exposures collateralised by the market value of recognised collateral
December 2019
December 2020
Art. 430(7) on draft ITS: Supervisory reporting June 2020 June 2020
Phase 2
Art. 396(3) of the CRR: Guidelines specifying the exceptional circumstances under which the large exposure limits may be breached and corrective measures
No deadline December 2021
Phase 3
Article 394(4) on draft RTS specifying the criteria for the identification of shadow banking entities
June 2020 December 2021
Art. 4(4) of the CRR: draft RTS on connected clients June 2020 December 2022 Art. 507(1) of the CRR: Report on the quantitative impact of the removal of, or the setting of a l imit to, some exemptions to the large exposures framework
June 2021 December 2021
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3. Roadmap for the delivery of the EBA mandates on Pillar 2
3.1 Introduction and background
57. The Directive amending the Capital Requirements Directive (CRD 5) entered into force on
27 June and it will apply on 29 December 2020 with the exception of some provisions, as set out
in Article 2 of the amending directive.14
58. This roadmap provides a general overview of the main changes included in the Pillar 2
framework stemming from the amended CRD (Title VII, Chapter 2) and CRR as well as an
overview of the deliverables on which the EBA plans to work in the coming months and years. It
also aims to provide a timeline for their completion.
59. This roadmap makes the link with the initial EBA Pillar 2 Roadmap that was published in April
2017.15 Furthermore, the roadmap also explains the planned changes to the Pillar 2 framework,
resulting from recent developments in the EU and international fora, as well as EBA findings
from the ongoing monitoring and assessment of convergence of supervisory practices. 16
60. In addition to the above, certain technical areas of the SREP Guidelines will be reviewed to
ensure consistency with other EBA regulatory products that have been issued after its
publication, in particular the EBA Guidelines on the management of non-performing and
14 Directive (EU) 2019/878 of the European Parliament and of the Council of 20 May 2019 amending Directive 2013/36/EU as regards exempted entities, financial holding companies, mixed financial holding companies, remuneration, supervisory measures and powers and capital conservation measures. OJ L 150, 7.6.2019, p. 253-295 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0878).
15 EBA outlines roadmap of its plan to update 2017-2018 SREP (https://eba.europa.eu/-/eba-outlines-roadmap-of-its-plan-to-update-2017-2018-srep).
16 As reflected in the most recent EBA Report on supervisory convergence, a good degree of progress was made by competent authorities in the implementation of the 2014 EBA Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) and supervisory stress testing. Areas still requiring attention include the proportionate approach of the SREP Guidelines, the roll -out of individual risk scores for smaller and non-complex institutions and technical guidance on internal capital/liquidity adequacy assessment processes (ICAAP/ILAAP) linkages and their assessment criteria.
EBA report on convergence of supervisory practices, EBA-Op-2019-02, 14 March 2019 (https://eba.europa.eu/documents/10180/2551996/Report+on+Convergence+of+Supervisory+Practices.pdf).
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forborne exposures,17 the EBA Guidelines on loan origination and monitoring18 and the revised
EBA Guidelines on outsourcing arrangements.19
61. The initial EBA Pillar 2 Roadmap, published in April 2017, set out a multi-stage approach for a
number of policy initiatives affecting Pillar 2 topics, including proposed changes driven by global
regulatory developments, and the EBA’s supervisory convergence assessments. That roadmap
led to the publication in July 2018 of a number of EBA guidelines aimed at reinforcing the Pillar 2
framework.20
EBA guideline Short title Date of application
Revised EBA Guidelines on common procedures
and methodology for the supervisory review and
evaluation process and supervisory stress testing
SREP Guidelines 1 January 2019
Revised EBA Guidelines on the management of
interest rate risk arising from non-trading
activities
IRRBB Guidelines 30 June 2019 (with
transitional
provisions until
31 December
2019)
EBA Guidelines on institutions’ stress testing Stress Testing
Guidelines
1 January 2019
62. The initial EBA Pillar 2 Roadmap already pointed to the necessity for a second revision of the
SREP Guidelines and the EBA Guidelines on the management of interest rate risk arising from
17 The EBA Guidelines on the management of non-performing and forborne exposures were developed in line with the action plan to tackle non-performing loans (NPLs) in Europe and preventing the build-up of NPLs in the future as set out by the European Council in July 2017. The guidelines are available on the EBA website (https://eba.europa.eu/regulation-and-policy/credit-risk/guidelines-on-management-of-non-performing-and-forborne-exposures).
18 EBA Draft Guidelines on loan origination and monitoring were published in June 2019 for public consultation until 30 September 2019 (https://eba.europa.eu/regulation-and-policy/credit-risk/guidelines-on-loan-origination-and-monitoring). 19 EBA Guidelines on outsourcing arrangements (https://eba.europa.eu/-/eba-publishes-revised-guidelines-on-outsourcing-arrangements). 20 Revised EBA Guidelines on common procedures and methodology for the supervisory review and evaluation proc ess and supervisory stress testing (https://eba.europa.eu/regulation-and-policy/supervisory-review-and-evaluation-srep-and-pillar-2/guidelines-for-common-procedures-and-methodologies-for-the-supervisory-review-and-evaluation-process-srep-and-supervisory-stress-testing).
Revised EBA Guidelines on the management of interest rate risk arising from non -trading activities (https://eba.europa.eu/regulation-and-policy/supervisory-review/guidelines-on-technical-aspects-of-the-management-of-interest-rate-risk-arising-from-non-trading-activities-under-the-supervisory-review-process).
EBA Guidelines on institutions’ stress testing (https://eba.europa.eu/regulation-and-policy/supervisory-review-and-evaluation-srep-and-pillar-2/guidelines-on-stress-testing2).
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non-trading activities (IRRBB Guidelines) after the publication of the revised Capital
Requirements Directive (Directive (EU) 2019/87)21 and Regulation (Regulation (EU) 2019/876).22
3.2 The EBA’s policy strategy on Pillar 2 deliverables
Changes to the Pillar 2 framework and mandates from CRD 5
63. CRD 5 made some changes to the Pillar 2 framework. In particular:
a. A focus on proportionality led to the introduction of simple and conservative
alternatives for smaller, less complex banks in terms of standards for and disclosures
and reporting of interest rate risks in the banking book;
b. In light of sustainable finance, the EBA is mandated to assess the potential inclusion of
environmental, social and governance (ESG) risks in the SREP review;
c. In view of the prudential supervisors’ role in complementing the role of anti-money
laundering (AML) authorities and participating actively in the fight against money
laundering (ML) and terrorist financing (TF), the AML dimension is highlighted in several
key prudential instruments such as the SREP23;
d. Pillar 2 capital add-ons are confined to a purely microprudential perspective in order
to avoid overlaps with the existing macroprudential tools that aim to address systemic
risk;
e. The conditions for applying Pillar 2 capital add-ons to cover specific risks to which a
bank is exposed are clarified and the institution-specific nature of those requirements
is emphasised. The add-ons are complemented by the possibility for supervisors to
express supervisory expectations for banks to hold additional capital under the form of
Pillar 2 guidance. The Pillar 2 guidance now also forms part of the joint decision on
institution-specific prudential requirements for EU cross-border banking groups;
f. The framework for the interest rate risk in the non-trading book (IRRBB) is modified
(in CRD 5 and CRR 2), introducing the credit spread risk in the banking book (CSRBB), as
well as a common standardised approach and a simplified standardised methodology
21 Directive (EU) 2019/878 of the European Parliament and of the Council of 20 May 2019 amending Directive 2013/36/EU as regards exempted entities, financial holding companies, mixed financial holding companies, remuneration, supervisory measures and powers and capital conservation measures. OJ L 150, 7.6.2019, p. 253-295 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0878).
22 Regulation (EU) 2019/876 of the European Parliament and of the Council of 20 May 2019 amending Regulation (EU) No 575/2013 as regards the leverage ratio, the net stable funding ratio, requirements for own funds and eligible liabilities, counterparty credit risk, market risk, exposures to central counterparties, exposures to collective investment undertakings, large exposures, reporting and disclosure requirements, and Regulation (EU) No 648/2012. OJ L 150, 7.6.2019, p. 1-225 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019R0876). 23 This is also in line with objective 3 of the Anti -Money Laundering Action Plan from the European Council adopted on 4 December 2018 to enhance supervisory convergence by providing common guidance on how to factor AML/CFT-related aspects into the prudential supervisory process: https://www.consilium.europa.eu/media/37283/st15164-en18.pdf
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for IRRBB, and adding the net interest income (NII) perspective to the economic value
of equity (EVE) perspective for the purposes of interest rate risk management,
disclosures and prudential supervision.
64. Alongside the changes listed above, the amended CRD and CRR include new mandates for the
EBA, being regulatory or implementing technical standards, guidelines or reports. The section
below details both the changes and the content of the mandates and provides some rationale
for the EBA’s intentions on the way forward on these mandates. In general, the EBA expects to
require a period of not less than 12 months to complete an assigned mandate in order to provide
high-quality work, noting the need to conduct full consultations with stakeholders.
65. Further to the changes in CRD 5, it is envisaged that the review of the SREP Guidelines will be
undertaken. The review will also aim to streamline and simplify the guidelines to facilitate their
application. The goal is to provide a common set of uniform guidelines that are fit for purpose
for the day-to-day work of supervisors.
66. The work on the review of the SREP Guidelines will take place in two phases. Areas that were
identified as high priority will be included in the first phase of the review, and areas identified
as medium priority will be included in the second phase. The revised SREP Guidelines will be
published at the end of the second phase. An earlier publication can be envisaged upon further
assessment for some of the high-priority areas in as far as the parts are stable and sufficiently
autonomous. In particular, an early publication on the incorporation of ML/TF risks into the SREP
process is planned because of the importance of the topic.
Proportionality
67. Proportionality is embedded in the current SREP Guidelines through the minimum engagement
model linked to the categorisation of institutions. The SREP Guidelines provide high-level criteria
for competent authorities to classify institutions into four categories according to their size,
structure, internal organisation, scope and nature and the complexity of their activities, also
reflecting the level of systemic risk. The SREP categorisation drives the minimum engagement
model, in which the frequency, depth and intensity of supervisory assessments vary depending
on the category of the institution.
68. Proportionality is a key focus of the revised CRD/CRR framework. In CRR 2, a definition of ‘small
and non-complex institutions’ is introduced. The definition is based on a set of quantitative and
qualitative criteria. The aim of the new definition is to allow smaller and less complex institutions
to bear less administrative burden and benefit from reduced disclosure requirements and from
simpler and more conservative prudential standards. This ties in with the overall goal for the
framework to be applied in a more proportionate way, taking into account the situation of
smaller and less complex institutions and the aim to reduce compliance costs for these
institutions.
69. The EBA is organising an impact assessment of the new CRR 2 definition of and will re-assess this
categorisation against the existing SREP categorisation used for the small and non-complex
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institutions. The assessment will also include a business model analysis that will complement
the view of the population of small and non-complex institutions with the characteristics of the
underlying institutions. The aim would be to align the SREP categorisation where relevant to the
new CRR 2 definition of ‘small and non-complex institutions’ and to ensure the consistency of
the proportionality approach across the different pillars.
70. In line with the mandate under Article 97(4a) of CRD 5, the EBA will reflect in its update of the
SREP Guidelines how similar risk profiles will be assessed for the purposes of the SREP in order
to ensure consistent and proportionate application of methodologies across the EU that are
tailored to similar institutions. For this work, the EBA will leverage on the experience of the
implementation of the existing SREP Guidelines and proportionality approaches and on the
outcome of the business model assessment. The aim is to provide a sufficiently granular
approach to proportionality and to maintain risk sensitivity for capital requirements under
Pillar 2.
71. The CRD does not contain a specific timeline to deliver this mandate. As the SREP Guidelines are
an important tool for supervisors, and a number of areas need to be reviewed based on the
revised CRD, it has been suggested that the revised SREP Guidelines be published by December
2021.
72. As proportionality affects all parts of the guidelines, this work will run throughout the review of
the SREP Guidelines.
Sustainable finance
73. The CRD/CRR review is part of the risk reduction measures aimed at further strengthening the
resilience of the banking sector. The goal is to promote financial stability, as well as contributing
to the harmonious and sustainable financing of economic activity.
74. In the light of sustainable finance, and pursuant to Article 98(8) of CRD 5, the EBA must submit
a report to the Commission by 28 June 2021 on the assessment of the potential inclusion of ESG
risks in the SREP.
75. Based on the outcome of this report, the EBA does intend to update the SREP Guidelines to
include guidance on how to include ESG risks in the SREP performed by competent authorities
following the update of the prudential framework regarding the duties of banks to incorporate
ESG factors into their financing and other activities.
76. As the inclusion of the ESG risks in the SREP Guidelines will depend on the outcome of the report,
their inclusion is expected to take place in a future update of the SREP Guidelines. We will look
at other ways of communicating expectations in the meantime.
Assessment of ML/TF risks from a prudential perspective
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77. As highlighted in the Commission Communication adopted in September 2018, 24 prudential and
AML supervision are complementary and need to go hand in hand. Therefore, prudential
supervisors of financial institutions need to consider AML-related aspects throughout their
work.
78. Further to Article 97(6) of CRD 5 and the Council of the EU’s action plan on AML,25 the EBA in
cooperation with prudential and AML/CFT (countering the financing of terrorism) supervisors
needs to enhance supervisory convergence by providing common guidance on how to factor
AML/CFT-related aspects into the prudential supervisory process, including in the context of the
supervisory assessment for the purpose of the SREP.
79. In view of the Council action plan on AML, and given the urgency of the need provide guidance
for the inclusion of AML/CFT-related aspects into the SREP, the work on this aspect will receive
priority in the review of the SREP Guidelines.
Microprudential perspective of Pillar 2
80. CRD 5 aims to make a clearer delineation of the areas of responsibility between competent and
designated authorities. Competent authorities are responsible for the SREP and the imposition
of corresponding institution-specific Pillar 2 capital requirements. In order for the Pillar 2
measures not to undermine the effectiveness of macroprudential measures, CRD 5 provides that
the SREP and Pillar 2 requirements should be confined to a purely microprudential perspective.
Therefore, no additional own funds requirement should be imposed to cover macroprudential
or systemic risk.
81. In the revision of the SREP Guidelines, it will be made clear that Pillar 2 requirements should be
set in relation to the an institution’s specific situation and should not be used to address
macroprudential risks.
82. These amendments will form part of the first phase of the revision of the SREP Guidelines. In
this context, also the relevant sections on the assessment of risks to liquidity, funding and
excessive leverage will be brought in line with the latest developments in the EU regulation. This
includes the introduction of the binding leverage ratio requirement, the additional leverage ratio
buffer for global systemically important institutions (G-SIIs) and the net stable funding ratio
(NSFR) under Pillar 1.
83. The alignment of the provisions in the SREP Guidelines with the new liquidity, funding and
leverage requirements will however take place in the second phase of the review of the SREP
Guidelines. As these provisions were not within the scope of the last revision of the SREP
Guidelines, some more elaborate work is needed. Given the recent application of the latest
24 Communication from the Commission, Strengthening the Union framework for prudential and anti -money laundering supervision for financial institutions, COM (2018) 645 final (https://ec.europa.eu/commission/sites/beta-political/files/soteu2018-anti-money-laundering-communication-645_en.pdf). 25 Council conclusions of 4 December 2018 on anti-money laundering action plan (https://www.consilium.europa.eu/media/37283/st15164-en18.pdf).
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requirements on these topics, it is deemed beneficial to gain sufficient experience on their
application before their integration into the SREP process.
84. Pursuant to Article 438(b) of CRR 2, institutions will be required to disclose the amount and
composition of additional own funds requirements based on the supervisory review process. In
the current SREP Guidelines, the questions of transparency and public disclosure of SREP
outcomes and supervisory measures, in relation to additional own funds requirements, are not
addressed. The new requirement under CRR 2 for institutions to disclose the Pillar 2 capital
requirements will be taken into account in the review of the SREP Guidelines.
85. The review of the SREP Guidelines in terms of transparency and disclosures of Pillar 2 capital
requirements will take place in the second phase of the review of the guidelines. This will allow
some time to discuss and coordinate with other bodies that are working on the matter. In view
of the importance of transparency, both the market and supervisory perspectives will require a
good common understanding.
86. The review of the SREP Guidelines will also provide the opportunity to align the treatment of
risks and definitions in the guidelines with the comprehensive supervisory risk taxonomy that is
currently under development to ensure a common understanding of the risks and their
categorisation.
87. In the course of the revision, the risk definitions will be aligned with those included in the final
taxonomy and the treatment of risks in terms of their categorisation will be aligned accordingly.
88. As mentioned, the common supervisory risk taxonomy will strengthen convergence in the
identification and assessment of risks and a consistent determination of Pillar 2 capital
requirements. In this respect, the revision of the guidance on the setting of Pillar 2 requirements
in the SREP Guidelines will leverage on the mapping in the supervisory risk taxonomy of all
prudential risks with the corresponding prudential tools according to their coverage of Pillar 1
or Pillar 2.
89. In view of the different areas that will need to be aligned with the common supervisory risk
taxonomy, and taking into account the timeline for the actual completion of the taxonomy, the
work on alignment will be done across both phases of the revision of the SREP Guidelines.
Pillar 2 capital add-ons and Pillar 2 guidance
90. Whereas the CRD 5 specifies that the Pillar 2 capital requirements need to be purely institution
specific, it also specifies the conditions for their application to cover the specific risks a bank is
exposed to. Furthermore, CRD 5 refers to the use of ICAAP calculations for the determination of
capital add-ons. Under Article 104b of CRD 5, the Pillar 2 capital add-ons are complemented by
the possibility for competent authorities to express supervisory expectations for banks to hold
additional capital under the form of Pillar 2 guidance. Pursuant to Article 113(1)(c) of CRD 5, the
Pillar 2 guidance should form part of the joint decision on institution-specific prudential
requirements in the framework of colleges of supervisors.
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91. In the revision of the SREP Guidelines, the conditions for setting Pillar 2 capital requirements, as
well as the use of ICAAP calculations for the determination of the capital add-ons, will be clarified
in line with the new CRD provisions. Provisions on the setting of Pillar 2 guidance were included
in the last revision of the SREP Guidelines and will be cross-checked to ensure full alliance with
the new CRD provisions.
92. In particular, the guidelines will need to be aligned with Article 104a of CRD 5 on the Pillar 2
capital coverage of risks or elements of risks identified as material pursuant to the SREP
assessment that are not covered or not sufficiently covered by the own funds requirements
under Pillar 1. For this, the work will leverage on the supervisory risk taxonomy that is currently
under development, which aims to ensure a common understanding of risks and their
categorisation to strengthen convergence in the identification and assessment of risks and
consistent determination of Pillar 2 capital requirements. The supervisory risk taxonomy will
map all prudential risks with the corresponding prudential tools according to their coverage of
Pillar 1 or Pillar 2, taking into account the changed landscape of the revised CRD/CRR
framework. This will provide greater clarity on how to apply and calibrate Pillar 2 for all risks,
having regard to the taxonomy agreed by the competent authorities.
93. The work on the inclusion of the Pillar 2 guidance into the joint decision process for EU cross-
border banking groups will be taken up in the planned revision of the ITS on joint decisions on
institution-specific prudential requirements.26
94. In view of the importance of supervisory convergence in the application of Pillar 2 capital
requirements and Pillar 2 guidance, both of which are important tools for supervisors, the
update of the related provisions in line with the new CRD will form part of the first phase of the
revision of the SREP Guidelines.
Framework for interest rate risk in the non-trading book (IRRBB)
95. As set out in the initial EBA Pillar 2 Roadmap, new international standards on the management
of IRRBB are implemented at the EU level in a multi-phased approach.27
96. In the first phase, the EBA Guidelines on the management of interest rate risk in the non-trading
book (IRRBB Guidelines) addressed to institutions were revised in the light of the new
26 Implementing Technical Standards on joint decisions on institution-specific prudential requirements (https://eba.europa.eu/regulation-and-policy/colleges-of-supervisors/draft-implementing-technical-standards-on-joint-decisions-on-institution-specific-prudential-requirements).
27 In particular the Basel Committee on Banking Supervision Standards on the management of IRRBB published in April 2016 (http://www.bis.org/bcbs/publ/d368.htm).
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standards. 28 In parallel, the guidance on the supervisory assessment of IRRBB in the SREP
Guidelines was also reviewed to align it with the new IRRBB Guidelines. 29
97. In the second phase, the interest rate risk framework in the revised CRD and CRR was amended
following the agreed international standards. The amendments include the introduction of a
common standardised approach, the requirement to monitor and assess CSRBB and the addition
of the NII perspective to complement the EVE for the interest rate risk management and the
supervisory outlier test.
98. The revised CRD also includes a number of mandates for the EBA to develop guidelines and
regulatory technical standards on IRRBB:
a. Under CRD Article 98(5a) of CRD 5, the EBA is mandated to submit to the Commission
by 28 June 2020 draft regulatory technical standards to specify for the purpose of the
supervisory outlier test on IRRBB (under the NII and EVE perspective) supervisory shock
scenarios, common modelling and parametric assumptions, excluding behavioural
assumptions, and what constitutes a large decline under NII.
b. Following Article 84(5) of CRD 5, the EBA is mandated to submit to the Commission by
28 June 2020 draft regulatory technical standards to specify a standardised
methodology and a simplified standardised methodology (for small and non-complex
institutions) that institutions may use for the purpose of identifying, evaluating,
managing and mitigating the risks arising from potential changes in interest rates that
affect both the EVE and the NII of an institution’s non-trading book activities.
c. Pursuant to Article 84(6) of CRD 5, the EBA is mandated to submit to the Commission
by 28 June 2020 guidelines to specify the criteria for the evaluation by an institution’s
internal system of IRRBB, for the identification, management and mitigation by
institutions of IRRBB, for the assessment and monitoring by institutions of CSRBB and
for determining which internal systems implemented by institutions for IRRBB
purposes are not satisfactory.
99. It must be recalled that the current EBA IRRBB Guidelines have applied since 30 June 2019 to
financial institutions30 and will remain in force until their revision in line with the mandate under
the revised CRD.
28 Revised EBA Guidelines on the management of interest rate risk arising from non -trading activities (https://eba.europa.eu/regulation-and-policy/supervisory-review/guidelines-on-technical-aspects-of-the-management-of-interest-rate-risk-arising-from-non-trading-activities-under-the-supervisory-review-process). 29 Revised EBA Guidelines on common procedures and methodology for the supervisory review and evaluation process and supervisory stress testing (https://eba.europa.eu/regulation-and-policy/supervisory-review-and-evaluation-srep-and-pillar-2/guidelines-for-common-procedures-and-methodologies-for-the-supervisory-review-and-evaluation-process-srep-and-supervisory-stress-testing).
30 The Guidelines include transitional arrangements for institutions that fall under SREP categories 3 and 4 to apply the provisions on the monitoring and assessment of CSRBB and on the additional EVE calculations under the six shock scenarios as from 31 December 2019.
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100. Following the finalisation of the technical standards and the revised EBA IRRBB Guidelines under
the CRD mandates, the section of the EBA SREP Guidelines on the supervisory assessment of
IRRBB management and controls will be aligned with the new IRRBB-related guidance for
institutions.
101. Depending on the final timeline for the development of the technical standards and the revision
of the EBA IRRBB Guidelines, the work on the revision of the IRRBB section of the SREP
Guidelines is expected to take place in a future update of the guidelines.
Other changes
New framework for investment firms
102. The scope of the SREP Guidelines will be reduced to credit institutions in view of the upcoming
new framework for investment firms under the Investment Firms Directive and Regulation
(IFD/IFR). 31 Whereas at present investment firms fall within the scope of the EBA SREP
Guidelines under the CRD, the current proposal of the IFD includes a mandate for the EBA to
develop SREP Guidelines specifically addressed to investment firms; hence, investment firms will
be removed from the scope of the SREP Guidelines under the CRD.
103. The amendment of the scope of the SREP Guidelines will be included in the first phase of the
review.
3.3 Expected timeline for deliverables
104. Based on the above, the tentative timeline for EBA deliverables is included in the following
figure. As explained before, the EBA normally requires a period of not less than 12 months to
complete an assigned mandate.
105. The tentative deadline for delivery of the revised SREP Guidelines is the end of 2021. This
timeline is indicative and the timing of the actual completion will depend on a number of factors.
Table 3: Timeline of mandates related to Pil lar 2 deliverables
Mandate Original
deadline Proposed deadline
Mandate related to SREP Guidelines
Art. 97(4a) of the CRD: Guidelines to specify how similar
risk profiles shall be assessed for the purposes of the SREP
No deadline December 2021
31 Proposal for a regulation of the European Parliament and of the Council on the prudential requirements of investment firms (IFR) (http://www.europarl.europa.eu/doceo/document/TA-8-2019-0378_EN.html?redirect).
Proposal for a directive of the European Parliament and of the Council on the prudential supervision of investment firms (IFD) (http://www.europarl.europa.eu/doceo/document/TA-8-2019-0377_EN.html?redirect).
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and to ensure the consistent and proportionate
application of methodologies across the Union that are
tailored to similar institutions.
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4. Roadmap for the delivery of the EBA mandates on resolution
4.1 Introduction
106. The bank recovery and resolution directive (BRRD), adopted in spring 2014, requires banks to
prepare recovery plans to overcome financial distress and grants national authorities powers to
pursue an orderly resolution of failing banks, ensuring that the banks' shareholders and creditors
pay their share of the costs. The EBA had delivered numerous mandates in order to enable an
effective implementation of this framework.
107. In April 2019, the European Parliament and the Council of the European Union adopted the
Banking Package, which included amendments to certain provisions of the BRRD and of the
Single Resolution Mechanism Regulation, but also to the Capital Requirements Directive (CRD)
and the Capital Requirements Regulation (CRR).
108. A part of the provisions in the package relates to MREL. In particular, it provides measures to
align the existing legislative framework with the relevant international standard issued by the
Financial Stability Board on the Total Loss Absorbing Capacity (TLAC) and includes significant
changes to the calibration, eligibility criteria and group allocation of the MREL requirement, and
the consequences of its breach. In addition, the text tackles the issue of contractual recognition
of bail-in for liabilities issued under third-country laws, as well as the powers of resolution
authorities to suspend payments (moratorium powers).
109. The Banking Package includes numerous new mandates for the EBA, being regulatory or
implementing technical standards (RTS or ITS), guidelines or reports. Through the delivery of
these mandates EBA will contribute to implement some outstanding elements to progress and
complete the European post-crisis regulatory reforms, in particular in order to achieve an
effective and credible bail-in tool through a strengthening of the MREL framework.
110. This roadmap focuses on the mandates received by the EBA related to the crisis management
framework. Within this scope, the EBA received a total of 14 related mandates distributed
between BRRD 2 and CRR 2.
111. The roadmap outlines the EBA’s plans for the delivery of those mandates and provides a timeline
for their completion.
4.2 The EBA’s policy strategy on resolution
112. The section below specifies the scope of the mandates and explains the rationale guiding the
roadmap.
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113. In its approach to prioritisation, the EBA has started from the timelines set out for each mandate
by the co-legislators. However, those timelines are very ambitious and they may not allow the
EBA sufficient time for an effective and practical delivery of all products for a variety of reasons,
including the need to agree on robust grounds across the EBA membership, relying on adequate
information and a common understanding of what are good policies to implement as well as the
need to properly consult an adequate range of stakeholders. Considering the time constraints,
in order to ensure that proper internal governance and public consultation processes are
followed, it is the EBA’s assessment that in general it will not be possible to deliver in less than
9-12 months.
114. The EBA has assessed the operational feasibility of delivering the mandates, taking into account
their volume and complexity and the relative resources required to deliver high-quality output.
Beyond the sequencing driven by the legislative deadlines, the mandates have been prioritised
on the basis of operational feasibility and with a view to minimising the impact on the progress
of resolution planning.
4.2.1 Mandates related to MREL eligible liabilities instruments
RTS on the definition of indirect funding and incentives to redeem eligible liabilities instruments —
Article 72b(7) of the CRR
115. These RTS should specify:
d. the applicable forms and nature of indirect funding of eligible liabilities, knowing
that, on the basis of Article 72b(2)(c) of the CRR, ‘Liabilities shall qualify as eligible
liabilities instruments if the acquisition of ownership is not funded directly by the
resolution entity’;
e. the forms and nature of incentives to redeem, for the purpose of the condition for
a liability to qualify as an eligible liability (Article 72b(2)(g) and Article 72c(3) of the
CRR).
116. These RTS should be fully aligned with the delegated acts that deal with the same issue for own
funds (Articles 28(5) and 52(2) of the CRR).
RTS on permission to reduce eligible liabilities instruments — Article 78a(3) of the CRR
117. These RTS relate to the redemption of eligible liabilities and what is commonly referred to as
the ‘permissions regime’ or ‘prior approval regime’. Importantly, the RTS require the EBA to
develop the procedure — in terms of coordination between competent and resolution
authorities, timelines and information — for resolution authorities to follow to provide prior
permission to banks to replace or reduce eligible liabilities instruments. The obligation to seek
approval applies to global systemically important institutions (G-SII) and other institutions with
minimum requirements for own funds and eligible liabilities (MREL) decisions higher than the
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loss absorption amount. In addition, the need to align these RTS with the RTS on the same topic
for the own funds regime is embedded in primary law.
118. These RTS are important for progressing resolution preparedness on the basis of the following:
f. As part of the CRR, the need for institutions to seek permission for the redemption
of eligible liabilities became immediately applicable on 27 June 2019. While the
European mandate is being developed, resolution authorities have to put in place
transitional arrangements. The absence of a European standard could give rise to
inconsistent practices applied to banks across Europe.
g. Although supervisory authorities have been dealing with such matters for some
time with respect to own funds instruments, this is generally a new role for
resolution authorities. It is important therefore that in this area the development
of a comprehensive approach is fully aligned with the own funds regime and that
the analysis of the related instruments leverages on the knowledge acquired from
capital instruments.
119. Although work on those mandates started immediately, the RTS cannot be completed in
6 months, as planned by the legislature. Beyond the usual governance and consultation
requirements for regulatory products, this is also due to the complexity of the topic and to the
need for the work to be developed in parallel to the work on own funds so that the redemption
regimes for both the ongoing and the completed topic can be aligned. However, given the
importance of such RTS to the authorities and the institutions, the deadline currently proposed
has to be considered at the latest.
Quality of own funds and eligible liabilities review — Article 80 of the CRR
120. The amended Article 80 of the CRR expands the existing mandate of the EBA from the review of
the quality of own funds to encompass MREL total loss-absorbing capacity (TLAC) eligible
liabilities. In this context, the EBA will draw on the methodology already established in the area
of own funds, in which it has published several reports32, to foster resolvability through high-
quality eligible liabilities.
4.2.2 Mandates related to MREL reporting and monitoring
ITS on MREL/TLAC reporting and disclosure — Article 45i(5) and (6) of the BRRD and Article 430(7)
and Article 434a of the CRR
121. These ITS require the EBA to develop a harmonised framework for reporting and disclosure of
MREL. The reporting of MREL from banks to resolution authorities in an automated and
standardised format is fundamental to allow authorities to efficiently monitor banks’
32 See EBA Report on the monitoring of CET 1 Instruments Issued by EU Institutions, 22 July 2019, and EBA Report on the monitoring of additional Tier 1 (AT1) Instruments of EU Institutions, 20 July 2019.
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compliance with their key requirements. Disclosure and reporting are closely linked and should
thus be developed together.
122. Work on these ITS has already started and public consultation should be launched shortly. The
ITS should be therefore delivered to the Commission by the deadline set (i.e. June 2020).
Report on MREL application, levels and shortfalls and Impact assessment report on MREL —
Article 45l(1) and (2) of the BRRD
123. The EBA is due to monitor the implementation and consistency of MREL across Europe. A report
on MREL application, levels and shortfalls based on 2018 data will be published by the end of
2019.
124. In Article 45l(1) of the BRRD, the EBA is required to submit to the Commission on an annual basis
starting in September 2020 a report on MREL application, levels and shortfalls. In addition to
this report, Article 45l(2) of the BRRD mandates the EBA to deliver every 3 years an impact
assessment of MREL in the EU banking sector on a number of aspects including financial markets
and the business models and balance sheet structures of institutions, with the first of such
reports to be delivered by the end of 2022.
Uniform templates for reporting MREL decisions to the EBA — Article 45j(2) of the BRRD
125. This mandate requires the EBA to update the existing ITS on reporting of MREL decisions by
resolution authorities to the EBA to ensure adequate reporting of MREL decisions for entities.
Although this mandate is relevant to monitoring the implementation of MREL across
jurisdictions in Europe, it does not have a direct impact on the progress of resolution planning.
Report on cross-holdings of MREL among G-SII and O-SII — Article 504a of the CRR
126. The EBA is to report to the Commission on the amounts and distribution of holdings of eligible
liabilities instruments among institutions identified as G-SIIs and other systemically important
institutions (O-SII). Based on the EBA report, the Commission will report by 28 June 2023 to the
European Parliament and to the Council on the appropriate treatment of such holdings and will
include a legislative proposal, where appropriate.
4.2.3 Mandates related to setting MREL
RTS on the methodology to estimate Pillar 2 requirement (P2R) and combined buffer requirement
(CBR) for resolution groups not subject to P2R under CRD 4 — Article 45c(4) of the BRRD
127. This mandate is for RTS that develop the methodology to be used by resolution authorities to
estimate the requirements for P2R and CBR for resolution entities, where the resolution group
is not subject to P2R requirements under CRD 4. This specific aspect should have an impact on
a minority of banks; it will be important, however, to consider the aspect of intense and
comprehensive cooperation between resolution and competent authorities.
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RTS specifying methods to avoid internal MREL instruments hampering the smooth implementation
of the resolution strategy — Article 45f(60 of the BRRD
128. These RTS relate to the topic of indirect funding for internal MREL specifying methods to avoid
instruments recognised for this purpose not ensuring proper transfer of losses to the resolution
entity and ultimately hampering the smooth implementation of the resolution strategy. The RTS
should specify a deduction regime (or an equivalent), ensuring that ‘daisy chain funding
structures’ are equivalent to direct funding and avoiding double counting of instruments.
129. This is an important issue to be addressed to ensure effective execution of the resolution
strategy, and policy will need to be developed taking into account the internal MREL practices
set in the meantime by resolution authorities. Although work on this mandate has already
started, the RTS cannot be completed in 6 months as planned by the legislature. Beyond the
usual governance and consultation requirements of regulatory products, this is also due to the
complexity of the topic.
4.2.4 Mandates related to contractual terms on bail-in and resolution stay powers
RTS specifying further clarification with regard to the exclusions from contractual recognition of
bail-in and ITS on notification to resolution authorities — Article 55(6)(8) of the BRRD
130. These mandates comprise RTS and ITS. The RTS require further clarification of (a) the conditions
under which it would be illegal or impracticable for an institution to include the contractual term
from Article 55(1), (b) the conditions under which the resolution authority requires the inclusion
of the contractual term and (c) a reasonable time in which the resolution authority requires the
inclusion. The ITS have to specify uniform formats and templates for the notification to
resolution authorities for the purposes of Article 55(2).
RTS determining the contractual terms required in financial contracts governed by third country law for the recognition of resolution stay powers — Article 71a(5) of the BRRD
131. These RTS require the EBA to further determine the contents of the term to be inserted in
contracts under third country law to recognise the resolution stay powers provided to resolution
authorities.
132. Providing clarity to banks with regard to the contractual terms they should be including in third
country law contracts will increase legal certainty and will facilitate the negotiations with
counterparties. However, not including such contractual terms required in accordance with
Article 71a(1) does not prevent authorities from using their relevant powers.
4.3 Expected timeline for deliverables
133. The tentative timelines for the EBA’s delivery of the resolution-related mandates set out under
BRRD 2/CRR 2 are detailed in the following table.
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134. For the reasons explained earlier, in particular the complexity of the issues and the need to
adhere to proper governance procedures, including public consultation processes, it is clear that
a significant number of the mandates will not be delivered within the timelines envisaged in the
texts of the directives and regulations. However, the approach taken should nevertheless
minimise the impact of the delay on the progress of resolution planning.
Table 4: Timetable of mandates related to resolution
Mandate Original
deadline Proposed deadline
Mandates related to MREL eligible liabilities instruments
Art. 72b(7) of the CRR: RTS on the definition of indirect funding and incentives to redeem eligible l iabilities instruments
December 2019
December 2020
Art. 78a(3) of the CRR: RTS on permission to reduce eligible l iabilities instruments
December 2019
December 2020
Art. 80 of the CRR: Quality of own funds and eligible liabilities review
N.A. Continuing
Mandates related to MREL reporting and monitoring
Art. 45i(5) of the BRRD and Art. 430(7) of the CRR: ITS on MREL/TLAC reporting
June 2020 June 2020
Art. 45i(6) and the BRRD and Art. 434a of the CRR: ITS on MREL/TLAC disclosure
June 2020 June 2020
Art. 45l(1) of the BRRD: Report on MREL application, levels and shortfalls
September 2020
September 2020
Art. 45l(2) of the BRRD: Impact assessment report on MREL December 2022
December 2022
Art. 45j(2) of the BRRD: ITS on MREL decisions reporting to the EBA
June 2020 December 2020
Art. 504a of the BRRD: Report on cross-holdings of MREL among G-SIIs and O-SIIs
June 2022 June 2022
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Mandates related to setting MREL
Art. 45c(4) of the BRRD: RTS on the methodology to estimate P2R and CBR for resolution groups not subject to P2R under CRD 4
December 2019
December 2020
Art. 45f(6) of the BRRD: RTS specifying methods to avoid internal MREL instruments hampering the smooth implementation of the resolution strategy
December 2019
December 2020
Mandates related to contractual terms on bail-in and resolution stay powers
Art. 55(6) of the BRRD: RTS specifying further clarification with regard to the exclusions from contractual recognition of bail-in
June 2020 December 2020
Art. 55(8) of the BRRD: ITS on notification to resolution authorities under Article 55 of the BRRD
June 2020 December 2020
Art. 71a(5) of the BRRD: RTS determining the contents of the contractual terms required in financial contracts governed by third country law for the recognition of resolution stay powers
June 2020 December 2020
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5. Roadmap on the delivery of the EBA mandates on Pillar 3 disclosures
5.1 Introduction and background
135. Following the recent updates to the regulatory frameworks for credit institutions and
investment firms, and the publication in 2018 of the European Commission’s action plan on
sustainable finance, the EBA is implementing a new strategy on its policy regarding institutions’
Pillar 3 disclosures that should foster the role of institutions’ disclosures in promoting market
discipline. The key targets of this strategy are:
a. optimise the Pillar 3 policy framework, providing a single comprehensive package
and thus improving clarity for users of information;
b. promote market discipline further, by increasing the consistency and comparability
of the information disclosed by institutions;
c. facilitate access for users of information to key information by introducing the new
key metrics templates;
d. foster ease of use for institutions by facilitating their access to and understanding
of all the disclosure templates and tables;
e. increase the efficiency of institutions’ disclosures and reduce costs via technology,
through the integration of quantitative data with supervisory reporting;
f. promote the awareness of external stakeholders of the relevance of the role of
institutions in the transition to a green economy.
136. The EBA will implement its Pillar 3 strategy through the development of the following
deliverables:
a. all-inclusive regulatory products, including:
i. comprehensive implementing technical standards (ITS), applicable to all
institutions subject to the disclosure requirements under Part Eight of the
Capital Requirements Regulation (CRR), including environmental, social
and governance (ESG) disclosures;
ii. comprehensive ITS on disclosure, applicable to all investment firms under
the scope of the new regulation on investment firms;
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iii. ITS on minimum requirement for own funds and eligible liabilities (MREL) and total loss-absorbing capacity (TLAC) disclosures, as defined in the Bank Recovery and Resolution Directive (BRRD) and Part Eight of the CRR;
b. integration with reporting, including mapping of all quantitative templates to
supervisory reporting;
c. the EBA disclosure data hub, which should serve as a single platform for users of
information to have common access to the quantitative data disclosed by
institutions in their Pillar 3 reports.
137. Currently, the EBA Pillar 3 policy framework is disseminated across a range of different
regulatory products, with a limited scope in terms of disclosures and institutions, following the
partial mandates included in the Level 1 text. The framework includes ITS and regulatory
technical standards (RTS) on disclosure of own funds, leverage ratio, countercyclical capital
buffers and asset encumbrance. It also includes guidelines on disclosures under Part Eight of the
CRR, mainly applicable to global systematically important institutions (G-SIIs) and other
systematically important institutions (O-SIIs); guidelines on disclosure of non-performing and
forborne exposures; and guidelines on disclosure requirements under the International
Financial Reporting Standard 9 (IFRS 9) transitional arrangements.
138. The EBA is in the process of implementing a comprehensive, more standardised approach in
terms of its policy regarding institutions’ Pillar 3 disclosures. This roadmap provides an overview
of the strategy that the EBA is planning to implement in the short and medium term, and the
timeline, process and deliverables that the EBA is deploying for this purpose.
139. The publication of CRR 2 and BRRD 2, the proposal for a regulation on the prudential
requirements of investment firms, the finalisation of the Basel III Pillar 3 framework and the EBA
strategic decision to integrate institutions’ reporting and Pillar 3 disclosure frameworks
constitute key milestones that have contributed to triggering and shaping the EBA’s strategy:
a. Both CRR 2 and BRRD 2 include a comprehensive overhaul of the Pillar 3 disclosures
with which institutions are required to comply. In addition, the amendments to the
Pillar 1 and Pillar 2 regulatory frameworks involve the need for further alignment
of institutions’ Pillar 3 disclosures with these changes. Both regulations include
mandates for the EBA to develop disclosure requirements.
b. The proposal for a regulation on the prudential requirements of investment firms
includes specific disclosure requirements for the investment firms within the scope
of the regulation and a mandate to the EBA to develop these disclosure
requirements.
c. The full review of the Basel Committee on Banking Supervision (BCBS) Pillar 3
standards as part of the Basel III post-crisis reform and the need for institutions’
information on their key risks to be comparable with that of their international
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peers are also key drivers of the EBA’s upcoming review of and change in strategy
on Pillar 3 disclosures, in alignment with the relevant international standards.
d. Finally, the commonalities of the information that institutions have to report to
their supervisors and the regulatory information that they have to make public in
the interest of investors and external stakeholders drove the EBA Board of
Supervisors’ strategic decision that consistency and integration between the
reporting and disclosure frameworks should be targeted to the extent possible.
The implementation of this decision should take into account the different levels
of granularity and that the objectives to be fulfilled are not the same.
140. In addition, the Commission’s action plan on sustainable finance, published in 2018, underlines
the relevance of the role of financial institutions in the transition to a sustainable economy, and
the importance of public disclosures as a tool to promote awareness and market discipline in
this transition.
141. As part of this action plan, large institutions that have issued securities that are admitted to
trading on a regulated market of any EU Member State are required to disclose information on
ESG risks from 28 June 2022, including physical risks and transition risks. Following the EBA
mandate to develop Pillar 3 disclosure requirements under Part Eight of the CRR, including for
the ESG risk-related disclosures, sustainable finance is another key aspect of the EBA’s strategy
on institutions’ Pillar 3 disclosures.
5.2 The EBA’s policy strategy on institutions’ disclosures
142. The key objectives of the EBA’s strategy in terms of policy on institutions’ Pillar 3 disclosures are
outlined below:
a. Optimise the framework, with more clarity for users of information: we will move
from a silo approach, with different policy products for different topics, to an
overarching policy product, with a more rational approach. The new framework is
being built with the aims of avoiding overlapping information in different templates
and promoting a sensible and comparable flow of information on different risks
and within the same risk/topic. In practice, this contributes to a more efficient
approach for institutions, through the elimination/merger of templates in which
similar or even redundant information was required.
b. Promote market discipline further, by increasing the consistency and
comparability of the information disclosed by institutions. This goal will be
achieved in several ways:
i. alignment with the Basel Pillar 3 standards, which will ensure
comparability of the information disclosed by EU institutions with their
internationally active non-EU peers;
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ii. fostering the use of fixed templates for the disclosure of quantitative
information;
iii. providing more standardisation by using common and clear definitions
and instructions that ensure that the qualitative and quantitative
information disclosed by institutions is comparable;
iv. in the case of quantitative information, comparability will be further
ensured through the integration with reporting, as the framework will
provide for each disclosure data point mapping to the relevant reporting
data points. The quantitative disclosure will benefit not only from the
application of common definitions but also from the validation rules
that are applicable to the relevant reporting templates, thus increasing
comparability and also reducing the risk of errors.
c. Facilitate access for users of information to key information by introducing the
new key metrics templates (one for prudential information and another for
resolution-relevant information) that will include the most relevant solvency,
liquidity and resolution indicators, and to the qualitative explanations that
institutions will have to provide for each type of risk and for the general risk
management policies and processes.
d. Foster ease of use for institutions by facilitating their access to and understanding
of all the disclosure templates and tables that they need to populate and disclose.
The EBA will achieve this through the implementation of a comprehensive single
policy framework, integrated in a single set of implementing standards. The new
comprehensive ITS will replace the existing various rules and regulatory products,
complementing them with templates and tables for those disclosure requirements
for which no uniform format is implemented in the EU.
e. Increase the efficiency of institutions’ disclosures and reduce costs via
technology, by ensuring that institutions do not have to disclose quantitative
information in addition to the data that they have to report. Once full integration
between reporting and disclosures is achieved, the new framework may allow the
EBA to further facilitate regulatory disclosures for small institutions by taking care
of their quantitative Pillar 3 disclosures.
f. Finally, promote the awareness of external stakeholders of the relevance of the
role of institutions in the transition to a green economy , encouraging institutions
to support their customers in this transition by implementing disclosures regarding
ESG risks. The EBA will develop ESG Pillar 3 disclosures, based on the mandate
included in the CRR in 2021, to be applicable from 2022, including disclosures of
climate change-related information such as a green assets ratio. As a step towards
facilitating these disclosures, and to inform the future EBA’s standards on ESG
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disclosures, the EBA could encourage voluntary disclosure of a limited number of
key metrics, which would facilitate the move towards full disclosure by credit
institutions based on the EBA technical standards.33
Proportionality in Pillar 3 disclosures
143. CRR 2 introduced definitions of ‘small and less complex institutions’ and ‘large institutions’ for
greater proportionality. The revised Pillar 3 framework is reflected in Part Eight, which defines
which disclosures are applicable to different institutions, depending on their size and complexity
and on whether they are listed or non-listed institutions. Small and non-complex institutions’
disclosures will focus on key metrics, while large and listed institutions will disclose more
detailed information.
144. Proportionality will also be reflected in the frequency of disclosures as well as in disclosure
formats, ensuring that enough information is conveyed to assess the risk profiles of different
institutions. In addition, the EBA will introduce thresholds to trigger additional disclosures for
large banks based on their risk profiles, to ensure that users of information have ‘sufficiently
comprehensive and comparable information for users of that information to assess the risk
profiles of institutions and their degree of compliance with the requirements laid down in Parts
One to Seven’.
The EBA as the EU Pillar 3 disclosure hub
145. The EBA and other regulators have taken significant steps to enhance and standardise regulatory
disclosures with the aim of increasing market discipline, consistency and comparability, and
making the use of disclosures more efficient. In addition, the EBA has contributed extensively to
improving understanding of the EU banking sector’s solvency, risks and exposures, and to
fostering market discipline in the single market, through its annual transparency exercise, which
provides the wider public with a consistent tool to access comprehensive data on the EU banking
system. However, the EBA sees room for further facilitating access to regulatory disclosures for
peer analysis.
146. The EBA is currently entering the final phase of upgrading its supervisory data platform, which
supports data collection, data validation, data integration and report monitoring. The
culmination of this work will establish the EBA as an EU-wide data hub, at the service of
competent authorities and the public. Building on this data infrastructure, the EBA intends to
establish an EU-wide hub for Pillar 3 disclosures. Individual institutions’ quantitative disclosures
would be available in one place, and information users would be able to download and use the
Pillar 3 information disclosed by all institutions from the EBA hub, in a harmonised format.
147. The current ongoing review of the Pillar 3 framework to deliver comprehensive, more
standardised disclosure requirements paves the way for the EBA to develop a more technical
framework for Pillar 3 disclosures, similar to the EBA supervisory reporting framework. A
33 The EBA plans to publish its action plan on sustainable finance in the near future; it will include a cross -reference to disclosures on and short-term policy actions in this field.
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standardised technical framework would allow the centralisation of information disclosed and
enable users to explore the data more easily and in a more systematic way.
148. This centralised disclosure hub would also provide an opportunity to further reduce compliance
costs for small and non-complex institutions. The EBA could be tasked with producing the key
metrics for Pillar 3 disclosures to exempt small institutions from this obligation. The hub would
centralise the Pillar 3 quantitative information not only for small institutions but also for large
and other institutions, for which the quantitative data that they have to disclose would be
disclosed also by the EBA. The disclosure hub would provide common access to EU institutions’
quantitative information, in a similar way to what the EBA currently does with the transparency
exercise but more comprehensively and using the Pillar 3 templates, which are aligned with
international standards. Initial steps in this direction have already been taken in relation to the
2019 EBA transparency exercise, for which two templates have been developed mirroring the
relevant Pillar 3 templates.
5.3 Expected timeline for deliverables
149. The main deliverables for the new disclosure strategy and framework will include the following.
a. Implementing technical standards:
iv. comprehensive ITS, applicable to all institutions subject to the disclosure
requirements under Part Eight of the CRR, including ESG disclosures;
v. comprehensive ITS on disclosure, applicable to all investment firms within
the scope of the new regulation on investment firms, implementing the
disclosure requirements on risk management objectives and policies,
governance, own funds, capital requirements, remuneration policy and
practices, investment policy and ESG-related risks;
vi. ITS on MREL and TLAC disclosures, as defined in the BRRD and Part Eight of
the CRR.
b. Mapping of all quantitative templates to supervisory reporting, data point by data
point, to facilitate institutions’ implementation.
c. In the medium/long term, the EBA disclosure data hub will serve as a single
platform for users of information to have common access to the quantitative data
disclosed by institutions in their Pillar 3 reports. The Pillar 3 hub could also support
small and other non-listed institutions in complying with their Pillar 3 quantitative
disclosure requirements.
150. The comprehensive ITS under Part Eight of the CRR will cover disclosure of the following topics:
a. risk management objectives and policies;
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b. scope of application;
c. own funds;
d. own funds requirements and risk weighted exposure amounts;
e. exposures to counterparty credit risk;
f. countercyclical capital buffers;
g. indicators of global systemic importance;
h. exposures to credit risk and dilution risk;
i. encumbered and unencumbered assets;
j. the use of standardised and internal ratings based (IRB) approaches (credit
risk);
k. exposures to market risk;
l. operational risk;
m. interest rate risk in the banking book (IRRBB);
n. exposure to securitisation positions;
o. ESG risks;
p. remuneration policy;
q. leverage ratio;
r. liquidity requirements (liquidity coverage ratio (LCR) and net stable funding
ratio (NSFR));
s. the use of credit risk mitigation (CRM) techniques.
151. The EBA plans to deliver the mandates following the timelines provided by the legislation, with
the aim of providing adequate time for implementation. The EBA’s target is to provide a 12-
month implementation period from publication of the final draft ITS on the EBA’s website to the
day when the first disclosures will take place.
152. The new ITS will include the disclosures on these topics based on CRR 2, BRRD 2 and the
Investment Firm Regulation (IFR). The EBA will review and amend as necessary the disclosures
on credit risk once the credit risk standardised approach regulatory framework is revised
following the implementation of Basel III. Similarly, once the Fundamental Review of the Trading
Book is closed, the EBA will conduct an extensive review of the market risk disclosures included
in the ITS in order to align them with the new framework.
Table 5: Timetable of mandates related to disclosure
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Mandate Product Disclosure topic Original Deadline
Proposed Deadline
1st disclosure date
Art. 434a of the
CRR: draft ITS specifying uniform
disclosure formats, and
associated instructions in
accordance with which the
disclosures
required under Titles II and III of
Part Eight of CRR shall be made.
Draft ITS on institutions’ public disclosures
Risk management objectives and policies
June 2020
June 2020
June 2021
Scope of application
Own funds
Own funds requirements and risk-weighted exposure amounts Counterparty credit risk
Countercyclical capital buffers
Credit risk and dilution risk
Encumbered and unencumbered assets
Use of standardised and IRB approaches (credit risk)
Market risk
Operational risk
Exposures to securitisation positions
Remuneration policy
Leverage ratio
Liquidity requirements (LCR and NSFR)
Use of CRM techniques
Indicators of global systemic importance
June 2020
Second half of 2020
June 2021
ESG risks June 2020
June 2021
June 2022
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IRRBB June 2020
Second half of 2020
June 2021
Art. 434a of the
CRR: draft ITS specifying uniform
disclosure formats, and
associated
instructions for the TLAC
disclosure requirements
Draft ITS on TLAC/MREL disclosures and reporting
TLAC June 2020
June 2020
Expected December 2020
Art. 45i(6) of the
BRRD: draft ITS specifying uniform
disclosure
formats, frequency and
associated instructions in
accordance with which MREL
disclosures shall be made
MREL June 2020
June 2020
2024
Art. 49 on draft ITS to specify
templates for disclosure of own
funds
Draft ITS on investment firms disclosures
Investment firms – Own funds
Expected June 2021
December 2020
Expected - June 2021
Art. 52 on draft ITS to specify
templates for disclosure of
investment policy
Draft ITS on investment firms disclosures
Investment firms – Investment policy
Expected June 2021
December 2020
Expected - June 2021
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6. Roadmap for the delivery of the EBA mandates on supervisory reporting
6.1 Introduction and background
153. The EBA has worked on harmonising and improving the reporting framework since its inception
in 2011. The EBA reporting framework is uniform and directly applicable, ensuring a level playing
field for institutions and comparability of data. The EBA reporting framework has evolved over
the years since the first reporting framework was published in 2013. The EBA has reviewed the
content to ensure its continued relevance, and it has also continued to develop the technical
package and version management to facilitate implementation and support reporting
processes.
154. The comprehensive reporting framework is of crucial importance to the day-to-day work of
supervisors, as it allows a standardised analysis of the strengths and weaknesses of individual
institutions. This analysis often forms the basis for more in-depth analyses performed through
on-site visits. Furthermore, it provides an overview —at both national and EU levels — of
systemic issues. Finally, it is of crucial importance as an analysis tool, for instance when it comes
to introducing new regulation or understanding specific aspects of the EU banking system in
more detail.
155. It is therefore clear that a strong and robust reporting framework is necessary. At the same time,
while improvements in reporting have been significant and there is a clear need for the reporting
framework, it is also clear that the framework has received its share of criticism, for instance for
not being sufficiently proportionate. In the light of significant revisions, the EBA wishes to
outline the overall principles behind the revisions to the framework.
156. While uniform and standardised EU-wide reporting requirements have been welcomed as
beneficial by institutions, there has been criticism with regard to proportionality, in particular
for small and non-complex institutions, the complexity of the requirements and definitions, and
consistency within the wider context of financial reporting requirements. Institutions have also
called for more coordination and data sharing by authorities to avoid overlapping additional
data requests, which offset some of the benefits of the EU single reporting framework. The EBA
intends to continue working on harmonisation, integration and coordination to meet these
challenges.
157. This roadmap provides an overview of the EBA’s work and strategy on supervisory reporting and
how it intends to continue its work to improve the reporting framework to meet the challenges
outlined above. First, the roadmap describes deliverables related to supervisory reporting that
the EBA will work on based on the new banking regulatory package and the forthcoming
regulation and directive for investment firms, as well as a timeline for their delivery. The EBA
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maintains on its website reporting frameworks with all related documentation as well as
information on short-term planning for framework releases. This roadmap sets out a longer
term plan for reporting deliverables.
158. Second, the roadmap provides an overview of the EBA’s work to increase the proportionality of
the reporting framework and to maintain the efficiency of the framework and reduce costs for
users. This work includes analyses and assessments of the costs and benefits of increasing
standardisation, the development of tools to help with the implementation of reporting and a
far-reaching feasibility study on a more integrated reporting approach that could further
increase efficiency across institutions and public authorities.
159. The mandates for reporting frameworks covered in this roadmap require the development of
the following:
a reporting framework based on CRR/CRR 2/CRD/CRD 5 (including the Backstop
Regulation);
a reporting framework based on BRRD/BRRD 2;
a reporting framework for investment firms based on the IFR.
160. The EBA’s work to increase the proportionality and enhance the efficiency of the reporting
framework covered in this roadmap includes the following:
a review of proportionality in the reporting requirements;
a study on the cost of compliance with reporting requirements (CRR 2 mandate);
a feasibility study on integrated reporting (CRR 2 mandate);
the integration of Pillar 3 disclosure requirements into supervisory reporting;
development of a reporting compliance tool;
changes to the reporting framework and implementation timelines;
validation rule management.
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Figure 1: Overview of the EBA’s work on reporting
General overview of EU supervisory reporting framework
161. The aim of the EU common supervisory reporting framework is to offer a single framework of
requirements for the prudential, resolution and financial reporting expected of credit
institutions and investment firms in the EU, thereby reducing the costs of reporting and fostering
a level playing field across EU institutions. It provides the foundation for the full harmonisation
of reporting on prudential requirements. The consistent application of the EU common
supervisory reporting framework is ensured by providing templates with related instructions, a
data point model and validation rules (as well as an XBRL taxonomy), supported by the Q&A
mechanism.
162. Commission Implementing Regulation (EU) No 680/2014 (implementing technical standards
(ITS) on supervisory reporting) and the other reporting standards34 that form the EU common
supervisory reporting framework need to be updated whenever the underlying regulatory
requirements change. Amendments to the ITS are also necessary to improve competent
authorities’ ability to effectively monitor and assess institutions’ risk profiles and obtain a view
of the risks posed to the financial sector.
34 ITS on supervisory benchmarking, ITS on resolution planning reporting and EBA guidelines on funding plans.
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EBA regulatory mandates on reporting
New banking regulatory package
163. The legislation adopting the banking package amends rules on capital requirements to reinforce
the capital and liquidity positions of banks under CRD 5 and CRR 2. It also strengthens the
framework for the recovery and resolution of banks under the revised BRRD 2 and the Single
Resolution Mechanism Regulation. The package includes numerous new mandates for the EBA,
requiring it to produce regulatory technical standards (RTS), ITS, guidelines and reports.
164. CRR 2 includes a number of key measures, such as amendments regarding the leverage ratio,
the new net stable funding requirement, a new market risk framework introduced in the form
of a reporting requirement and a new total loss-absorbing capacity (TLAC) requirement. Besides
these changes to the substance of the prudential framework, the reporting and disclosure
requirements themselves have been subject to amendments. Moreover, BRRD 2 introduces a
new requirement on the loss-absorbing and recapitalisation capacity of credit institutions and
investment firms. It is therefore necessary to update the ITS on supervisory reporting to ensure
the collection of information to reflect those new rules.
165. The package also aims to enhance proportionality, as the new rules are more growth-friendly
and better able to be adapted to the size, risk and systemic importance of the banks.
Proportionality is also reflected in the EBA’s proposals for reporting requirements, as well as in
the cost of compliance study on reporting and the feasibility study on integrated reporting that
the EBA is mandated to submit to the European Commission by CRR 2.
Regulation on minimum coverage of non-performing exposures
166. In addition to the changes stemming from the risk reduction package, the European Council
published its conclusions on an action plan designed to tackle non-performing loans (NPLs) in
Europe in July 2017. In its action plan, the European Council requests that the European
Commission consider introducing prudential backstops to address potential under-provisioning
of non-performing exposures (NPEs). The backstop would apply to newly originated exposures
in the form of compulsory prudential deductions from institutions’ own funds.
167. Following this request, Regulation (EU) 2019/30 of the European Parliament and of the Council
amending Regulation (EU) No 575/2013 (the Backstop Regulation) was published in April 2019.
It introduced a Pillar 1 measure that directly applies to all institutions subject to the CRR. In
particular, the Backstop Regulation sets out uniform minimum levels of coverage to ensure that
institutions have sufficient loss coverage for future NPEs. Consequently, the reporting
framework will have to be expanded to cover this new element.
Investment firms’ regulatory package
168. Moreover, the IFR and the IFD completed the trilogue on 26 February 2019 and are expected to
be published in the Official Journal by the end of 2019. The EBA mandates cover a broad range
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of areas related to prudential treatment of investment firms, and one of them is to develop a
completely new reporting framework for investment firms; in contrast to the situation today,
investment firms — with the exception of the very largest investment firms — will be subject to
a separate regime.
6.2 The EBA’s policy strategy on supervisory reporting
169. The uniform supervisory reporting framework brings significant benefits to all stakeholders, but
the EBA is also cognisant of the need to maintain and enhance the efficiency of the reporting
framework and that changes to reporting requirements entail costs for institutions. Therefore,
the EBA has taken action and is reviewing the measures taken to design and maintain an efficient
framework that balances costs and benefits.
170. The EBA’s key objectives in terms of its strategy for developing and reviewing its reporting
framework are as follows:
Fit-for-purpose: the information reported should reflect the underlying regulations and
should enable supervisory and resolution authorities to fulfil their tasks and duties.
Supervisory data are essential for effective supervision and thus they are vital for
achieving the EBA’s objective of protecting the public interest by contributing to the
short-, medium- and long-term stability and effectiveness of the financial system, for the
EU’s economy, its citizens and its businesses. The reporting requirements should be
tailored to cover the information that the authorities need to carry out their tasks.
Measures/actions taken: regular review of reporting requirements, in line with the
development of the EU banking regulatory framework, with the aim of strengthening the
quality and effectiveness of supervision.
Proportionality: while reporting should capture all necessary information, it should also
be proportionate to the nature, scale and level of risk of institutions’ activities.
Proportionality should be considered not only in the reporting requirements but also in
the wider context of reporting efficiencies to ensure that the reporting infrastructure is as
user-friendly as possible and allows the use of technology to reduce costs.
Measures/actions taken: on the one hand, reporting requirements implicitly depend on
regulatory approaches and institutions’ business models and activities (e.g. the use of
internal models for credit risk; issuance of covered bonds or securitisations); on the other
hand, template-specific materiality thresholds and risk-based criteria are provided to
trigger certain reporting requirements, in order to take into account the nature, complexity
and riskiness of institutions’ activities. The EBA will conduct a full review as part of its study
on the cost of compliance with reporting requirements. The EBA is also continuing its work
on facilitating implementation and compliance to reduce costs.
Data standardisation and consistency: the EBA’s supervisory reporting is harmonised and
in the vast majority of cases subject to ‘maximum harmonisation’. The framework is
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directly applicable in the EU and the EBA provides detailed data definitions in the form of
a standardised data dictionary for each reported item to ensure the uniform
implementation of the reporting requirements. The concepts and definitions are
consistent within the EU banking regulatory framework, within the EBA framework and
among the different reporting requirements within the financial sector to ensure
comparability of information.
Measures/actions taken: the development of the EBA’s data point model and the common
dictionary; the implementation of a consistent design across the whole framework; the
promotion of the use of legal entity identifier codes in all supervisory reporting; efforts to
foster consistency among and integration of all regulatory reporting requirements for
institutions. The EBA reporting framework fully integrates prudential, financial and
resolution reporting into one common dictionary. The integration of reporting and
disclosures will increase consistency and facilitate the implementation of both sets of
requirements.
6.2.1 Upcoming changes to the EBA reporting framework
171. The EBA issues new reporting requirements in framework releases, in an annual framework
release or in releases by module to accommodate different development and application
timelines, which often are defined by the underlying regulations.
172. The EBA completed framework release version 2.9 (phases 1 and 2) in August 2019 and is
currently preparing release version 2.10, which will have a more limited impact, with a focus on
funding plan reporting. The next major framework release will be version 3.0, into which
changes and new reporting requirements resulting from CRR 2, CRD 5 and BRRD 2 will be
incorporated. The EBA maintains on its website all versions of the reporting frameworks,
including legal texts, reporting instructions and technical documentation, together with a
calendar to help institutions with their planning and with implementing the requirements.
173. Some planned changes that go beyond version 3.0 are already identifiable, such as reporting by
investment firms, changes resulting from the completion of Basel III and amendments to
reporting by institutions using the internal-ratings based (IRB) approach stemming from the
completion of the IRB roadmap and the final new market risk requirements.
174. The planned deliverables for version 3.0 of the EBA reporting framework are:
new ITS on supervisory reporting that will replace Commission Implementing Regulation
(EU) No 680/2014 for consistency and legal certainty reasons;
new ITS on reporting on the new market risk requirements;
new ITS on minimum requirement for own funds and eligible liabilities (MREL)/TLAC
reporting and disclosures;
amendments to the ITS on supervisory benchmarking.
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Prudential and financial reporting
Reporting changes resulting from CRR 2 and the Backstop Regulation
Credit risk
175. The main changes to the credit risk framework will be closely related to changes in CRR 2
(infrastructure projects to support investment and revised provisions on exposures to collective
investment undertakings) and adjustments to supervisory reporting to achieve consistency with
the newly developed framework for IRB approach and standardised approach (SA) disclosures.
176. The IRB framework will be further adjusted in the following reporting framework release in
order to implement the regulatory products from the EBA IRB roadmap. 35 The EBA is mindful
that the implementation of Basel III will require more substantial changes to SA reporting, and,
consequently, it envisages at the moment only changes to align reporting with disclosures.
Market risk
177. While the currently applicable market risk framework and the related exist ing reporting
requirements will remain unchanged in the next reporting release, CRR 2 introduces the first
elements of the Fundamental Review of the Trading Book (FRTB), initiated by the Basel
Committee on Banking Supervision (BCBS), into the prudential framework of the EU. Despite not
yet being binding in terms of own funds requirements, the framework is implemented by means
of a reporting requirement, constituting the first step towards the full implementation of the
FRTB framework in the EU.
178. The reporting requirements on the new market risk framework will be gradually expanded; the
first step will be to introduce a thresholds template, providing insights into the size of
institutions’ trading books and the volume of their business subject to market risk, and a
summary template, reflecting the own funds requirements under the alternative standardised
approach (ASA). Later, this information will be complemented with details on the calculation of
the own funds requirements under the ASA and by information on the own funds requirements
under the alternative internal model approach.
179. The EBA is taking a gradual approach because it is mindful of the importance of expanding the
reporting requirements resulting from the FRTB in a proportionate manner, as institutions will
also continue to be subject to the current market risk framework and the associated reporting.
Once clarity on the full implementation of the FRTB framework in the EU exists — including
clarity on the implementation of the EBA roadmap on market risk and counterparty credit risk
— the framework will be expanded to fully cover the new requirements.
35 See the EBA’s progress report on the IRB roadmap: https://eba.europa.eu/documents/10180/2551996/Progress+report+on+IRB+roadmap.pdf
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Counterparty credit risk
180. CRR 2 revised the counterparty credit risk framework and introduced new approaches to
calculating own funds requirements for counterparty credit risk. In supervisory reporting,
counterparty credit risk has so far been captured only at a very high level in the credit risk
templates. A set of new templates will be developed, as recommended in the EBA’s advice to
the European Commission on SA counterparty credit risk and own funds requirements for
market risk (November 2016), to improve supervisors’ ability to monitor and assess institutions’
counterparty credit risk profiles and their compliance with the new requirements.
Liquidity — net stable funding ratio
181. CRR 2 implemented the net stable funding ratio (NSFR) for institutions in the EU. The NSFR is
aimed at ensuring that the required stable funding that is expected at different points in time is
held in the form of adequate, available stable funding. An adequate supervisory review of the
compliance of institutions with the NSFR minimum requirement necessitates proper NSFR
reporting in accordance with the specifications set out in CRR 2. To achieve this, a set of new
templates will be developed to replace the NSFR monitoring templates.
182. CRR 2 also envisages simplified requirements for small and non-complex institutions, which will
be reflected in a set of simplified templates.
Leverage ratio
183. CRR 2 has introduced the 3% leverage ratio requirement for institutions in the EU, as well as a
global systemically important institution (G-SII) buffer requirement for G-SIIs. In addition, there
are several changes to the definition of leverage ratio exposures from that used in the leverage
ratio delegated act of October 2014. These changes mostly reflect the changes in the definition
of the leverage ratio in the 2017 BCBS revised framework. Furthermore, there are a number of
EU specificities, often leading to the exemption of certain exposures from the leverage ratio
calculation.
184. The reporting requirements will be updated in line with the changes to the regulatory
framework, to take into account the new SA for counterparty credit risk, to include the Pillar 2
requirements that address risks of excessive leverage and to reflect the G-SII buffer
requirement, among other things. The amended leverage ratio reporting will also require large
institutions to report averages of specific components of the leverage ratio calculation, to
enable the authorities to monitor the volatility of the leverage ratio.
Non-performing exposures: the Backstop Regulation
185. Following the Backstop Regulation, new reporting requirements will be introduced in both the
Financial Reporting Framework (FINREP) and the Common Reporting Framework (COREP).
186. The COREP framework will include templates on NPE loss coverage that will allow supervisors
to obtain information on the amount of NPEs subject to the Backstop Regulation and the amount
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of deductions from Common Equity Tier 1 (CET1) capital, as well as to monitor the backstop
calculation by time passed since an exposure’s classification as non-performing.
187. The FINREP amendments will cover the stock of NPEs, by time passed since an exposure has
been classified as non-performing, to allow supervisors to monitor institutions’ NPE coverage
strategies more effectively and capture their risk profiles more accurately. Furthermore, the
definition of NPEs and forbearance will be removed from the FINREP instructions, given that
they are now included in the CRR itself.
Large exposures
188. Large exposure reporting will be reviewed to reflect amendments in CRR 2. These changes will
include the calculation of large exposure limits based on CET1 capital rather than eligible capital
and the removal of the requirement to report maturity buckets of an institution’s 10 largest
exposures on a consolidated basis to institutions and to shadow banking entities.
189. Further amendments to large exposure reporting may result from and take place after the
regulatory mandates on large exposures have been delivered.
Liquidity — additional liquidity monitoring metrics
190. CRR 2 mandates the EBA to identify which additional liquidity monitoring metrics (ALMM) will
apply to small and non-complex institutions. The EBA will assess the best way to achieve this
simplification in the context of the study on the cost of compliance with reporting requirements.
Own funds
191. Amendments to the own funds module will result from changes in the CRR 2 own funds and the
integration with the Pillar 3 framework.
Other amendments
FINREP
192. Amendments to FINREP will be driven by accounting issues (e.g. the presentation of purchased
and originated financial assets outside the impairment stages of International Financial
Reporting Standard 9 (IFRS 9)); Q&As (e.g. the inclusion of cash balances and other demand
deposits in loss allowance movements); and the need for integration with the Pillar 3
framework.
Asset encumbrance
193. Minor amendments to the asset encumbrance module will result from the integration with the
Pillar 3 framework.
Losses from immovable property
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194. Reporting on losses from immovable property (IP losses) will be amended with regard to the
reporting frequency (from semi-annual to annual), as mandated by Article 430(a) of the
amended CRR. A further review of the underlying methodology for reporting IP losses will be
undertaken during 2020.
Operational risk
195. Reporting on operational risk will not change as a result of CRR 2, and consequently no
significant changes are expected. Furthermore, it would appear premature to make any
changes, as the EU implementation of Basel III is likely to include the introduction of a
completely new framework.
Liquidity — liquidity coverage ratio
196. New reporting on the liquidity coverage ratio (LCR) will begin from April 2020, and no further
major amendments are planned.
Supervisory benchmarking
197. Supervisory benchmarking reporting is being reviewed on an annual basis, to implement any
changes to the market risk and credit risk portfolios and to the reporting templates and
instructions needed to keep the portfolios up to date and the reported data relevant for the
EBA’s supervisory benchmarking exercise.
198. The latest update reduced the portfolios to be reported on by 70-80%, thus reducing the
reporting burden significantly. Furthermore, in line with the responses to the latest revision,
limited changes are expected to the existing templates, in the form of consistency
improvements and alignments with the existing framework. The intention, therefore, is to
maintain stability in the current reporting framework.
199. At the same time, however, the EBA is scrutinising the effective implementation of IFRS 9 in the
EU, and the quantitative monitoring involves work on the benchmarking of the modelling
techniques used by EU institutions for IFRS 9 purposes. 36 The integration of selected IFRS 9
parameters into the ITS on supervisory benchmarking is expected to be implemented in two
phases in 2020 and 2021.
Funding plans
200. Funding plan reporting is currently undergoing a major revision, which will be completed in
December 2019.
Resolution reporting
36 See the EBA’s roadmap for IFRS 9 deliverables: (https://eba.europa.eu/documents/10180/2551996/Roadmap+for+IFRS+9+deliverables.pdf)
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TLAC/MREL
201. The new banking package implements the Financial Stability Board’s TLAC standard in the EU
and complements the MREL that has been in force since 2014. TLAC — formally the ‘G-SII
requirement for own funds and eligible liabilities’ — applies to G-SIIs only. The reporting and
disclosure obligations on TLAC are already in force.
202. Even though MREL and TLAC have their origins in different Level 1 texts, they will be presented
in the reporting and disclosure framework in an integrated manner, to emphasise the
differences and commonalities of the two prudential concepts.
203. Unlike TLAC, MREL applies to the broader population of institutions (G-SIIs and non-G-SIIs). For
G-SIIs, the MREL is composed of the TLAC requirement and an MREL add-on. MREL and TLAC are
based on the same core of own funds and eligible liabilities, with limited elements specific to
each requirement: a deduction regime for TLAC; restrictions on the admissibility of senior debt
to TLAC; and a broader eligibility of structured notes for MREL.
204. The new templates will provide information on the amount and composition of institutions’ loss-
absorbing capacity; facilitate comparisons between the prudential ratios and the requirements
determined on the basis of, among other things, the resolution planning framework; and include
information on the ranking of own funds and eligible liabilities in insolvency proceedings, as well
as contract-by-contract information that will provide insights, for example, into the relevance of
third countries’ laws in the event of resolution.
205. In line with the co-legislators’ specifications, the EU’s harmonised disclosure and reporting
requirements will apply only to entities and groups that would be resolved in the event of severe
financial or other difficulties, rather than being subjected to the conventional insolvency
proceedings and being liquidated. The information to be provided depends on the type of entity
— whether the entity or group in question is a resolution entity or group or another entity —
and, in the case of disclosure on TLAC, also on the size of the entity or group in question.
Resolution planning reporting
206. The updated ITS on resolution reporting was published in 2018 and no major revisions are
currently planned. Minor revisions may take place to rectify errors and reflect the guidance
provided by Q&As.
Reporting by investment firms
207. Investment firms have been subject to the same requirements that the CRR and the CRD set out
for credit institutions. However, because of their specificities, a specific framework was
developed. The new framework is being finalised to take into account the prudential
requirements set out in the IFR and the prudential supervision described in the IFD.
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208. The IFD and the IFR provide specific and more proportionate requirements for investment firms,
taking into account their size, nature and complexity. The largest firms will be subject to the full
banking prudential regime and will be supervised as credit institutions.
209. The new framework sets out reporting and disclosure requirements that will be designed in
accordance with the standard formats and definitions to ensure consistency in the requirements
of Pillar 3 and supervisory reporting.
210. The IFR mandates the EBA to submit the ITS on reporting and the ITS on disclosures 12 months
and 18 months, respectively, after the entry into force of the IFR. The EBA plans to provide the
Consultation Paper in 1H 2020 and submit the final ITS in 2H 2020.
6.2.2 The EBA’s work to increase the proportionality and enhance the efficiency of the reporting framework
211. Increasing the proportionality of the reporting framework is one of the EBA’s key objectives for
reporting, and this issue is also highlighted in the new banking regulatory package. The EBA’s
view is that proportionality should be considered not only in the design of the reporting
requirements but also in the wider context of reporting efficiencies to ensure that the reporting
infrastructure is as user-friendly as possible and allows the use of technology to reduce costs.
212. The EBA is working on delivering a more proportionate reporting framework. This includes not
only a review of the current reporting framework but also analyses and assessments of the costs
and benefits of increasing standardisation, the development of tools to help with the
implementation of reporting and a more far-reaching feasibility study on a more integrated
reporting approach.
Proportionality in reporting requirements
213. Proportionality has been implemented in the supervisory reporting framework with the aim of
striking a balance between reducing the costs of reporting (implementation and ongoing costs)
for institutions and ensuring the quality and effectiveness of supervision. This is achieved using
various approaches.
214. Many elements of proportionality in supervisory reporting are implicit, as they are driven by the
regulatory regime, or by the prudential approach or the business model of the institution. For
example, the scope of the data to be submitted depends on factors such as if an institution is
subject to resolution, if internal models are used to calculate own funds requirements and if an
institution has issued covered bonds or securitisations.
215. The supervisory reporting framework also incorporates different, tailored reporting frequencies
and includes defined size- and risk-specific criteria and thresholds to trigger certain reporting
requirements (e.g. on sovereign exposures, large exposures, geographical breakdowns, details
of NPEs), to take into account the nature, complexity and riskiness of institutions’ activities.
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216. CRR 2 introduced definitions of ‘small and less complex institutions’ and ‘large institutions’ for
greater proportionality. The EBA will review all the criteria and thresholds on size and complexity
and streamline them, referring to the CRR definitions for small and large institutions where
suitable. These CRR size categories will be used across the reporting framework, for example to
exempt small institutions from some reporting requirements or to trigger additional reporting
requirements for large institutions.
217. In the current framework, when a simplistic measure of count of reported data points is used,
on average large institutions report up to 10 times more data points than small institutions.
Notwithstanding, the EBA considers it worthwhile to increase proportionality, and it would also
be in line with the new concepts introduced by CRR 2. Further input on how greater
proportionality can be achieved is expected from the report on costs and benefits of compliance
with reporting requirements that the EBA has been mandated to submit to the European
Commission by CRR 2.
EBA report on the costs and benefits of reporting requirements
218. As part of its overall work on introducing greater proportionality into the regulatory and
supervisory frameworks, and reducing the costs of compliance for institutions, the EBA has been
mandated to assess the costs and benefits of compliance with common supervisory reporting
and to suggest ways to reduce reporting costs by 10-20%, at least for small and non-complex
institutions.
219. The study offers an opportunity to verify the assumptions behind and check the effectiveness of
the proportionality elements in the ITS, as well as to revisit and revise them, if needed. In
addition, it may provide insights into the cost drivers, which may serve as a basis for improving
the reporting requirements — that is, making them less costly for institutions.
220. The study will follow closely the requirements of the CRR mandate (Article 430(8)) and will
involve two stages: (1) the classification of credit institutions into categories based on their size,
complexity and the nature and level of their activities; and (2) an evidence-based analysis of the
reporting costs and their proportionality and benefits for the purposes of prudential supervision,
assessing the effects of reducing reporting requirements on the effectiveness of prudential
supervision and making recommendations on how to reduce reporting requirements.
221. The results of the study and related policy recommendations are expected to be delivered to
the European Commission and published by the end of 2020.
EBA feasibility report on integrated reporting
222. Since the financial crisis, new reporting requirements have been recognised as key for
supervisory, financial stability and statistical purposes. The development of these reporting
needs has sometimes led to some overlaps. In addition, ad hoc requests and national
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requirements have offset some of the benefits of a single set of harmonised reporting
requirements across the EU (Commission call for evidence report, 201737).
223. EU legislators have considered concerns about the reporting burden and the need to improve
the efficiency of reporting and have included in the CRR 2 a mandate to the EBA to prepare a
feasibility report for the development of a consistent and integrated system for collecting
statistical, resolution and prudential data and report its findings to the Commission
(Article 430(c)).
224. The current EU reporting ecosystem consists of many different actors (reporting entities and
authorities) and reporting frameworks (supervision, statistics, etc.), including the different
national, European and international requirements.
225. Following the mandate, the EBA will involve competent authorities, as well as authorities in
charge of deposit guarantee schemes, resolution authorities and in particular the European
System of Central Banks (ESCB), in the feasibility study. The feasibility report should also take
into account the work that the ESCB has already carried out regarding the integration of data
collections. Close interaction with other stakeholders is also important and will take place
through bilateral meetings, workshops and consultations from the fact-finding, scoping phase
to the final report.
226. The report will consider feasibility in the short and long term, or different integration options,
and will be based on a cost and benefit analysis, taking several issues into consideration; the
quantity and scope of the current data collected; the use of a common data dictionary; the
establishment of a joint committee; and the feasibility and possible design of a central data
collection point.
227. For the feasibility study, the EBA will build on the objectives of an integrated system, which
include (1) increasing the efficiency of reporting by standardising reporting, reducing
redundancies and using common definitions; (2) increasing efficiencies for financial entities; (3)
facilitating the exchange of data and its usability; and (4) improving data quality. Therefore, to
achieve these objectives, understanding the cost drivers of institutions’ reporting processes and
how to improve the usability of data for the public sector are key.
228. In addition, the data ecosystem that may result from the feasibility report should be future-
proof, that is, not only relevant under the current circumstances but also relevant and applicable
in the future, even with changes in the reporting environment. As part of this assessment, the
EBA will also consider and analyse a possible shift from the current approach, focused mainly on
aggregated data, towards more granular reporting.
37
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS, Follow up to the Call for Evidence - EU regulatory framework for financial services, 1.12.2017, https://ec.europa.eu/info/files/171201-report-call-for-evidence_en
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229. With these objectives in mind, integrated reporting will be considered from different angles as
part of the feasibility study:
organisational: common governance, common data collection, common monitoring of
data quality;
methodological: a common dictionary, common definitions, common transformation and
calculation rules;
legal: the level of harmonisation, reporting requirements, access rights/sharing of
information;
technological: common data processes, a central collection point, a shared platform.
230. The preparation of the report for the Commission has been divided into two separate phases:
(1) fact-finding and research, aimed at scoping the report and investigating currently existing
initiatives on the integration of reporting; and (2) a detailed analysis and assessment of the
options identified during the first phase. The results from phase 1 of the report are expected to
be ready by H1 2020, and phase 2 of the report will be presented for consultation by H1 2021.
231. The EBA will interact closely with stakeholders during both phases of the report preparation. As
part of the fact-finding (phase 1), the EBA has already started to engage with competent
authorities and other stakeholders to gather information on the data currently collected, the
reporting process, dictionaries and technologies.
Integration of Pillar 3 disclosure requirements into supervisory reporting
232. The commonalities of the information that institutions have to report to their supervisors and
the regulatory information that they have to make public in the interest of investors and external
stakeholders drove the EBA Board of Supervisors’ strategic decision that consistency and
integration between the Pillar 3 disclosure and supervisory reporting frameworks should be
targeted to the extent possible. To ensure consistency, the integration of supervisory reporting
and disclosures will be carried out throughout the whole review of reporting and disclosure
requirements.
233. The information included in the reporting framework is the basis on which supervisors and
resolution authorities form a clear picture of the situation of an institution in terms of business
model/profitability, solvency/risk profile, liquidity, relevance for the financial system and
resolvability. Similarly, the information disclosed by institutions is the basis on which market
participants understand and assess institutions’ situations in order to exercise market discipline.
Information relevant for market participants is also relevant to help supervisors with their tasks,
hence the importance of striving for congruency.
234. Increasing consistency between reporting and disclosure requirements, including a
standardisation of formats and definitions, should also facilitate institutions’ compliance with
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both requirements, as they will be able to use the same data to fulfil their reporting and
disclosure obligations. Furthermore, the integration of disclosure requirements with supervisory
reporting will improve the quality of the information disclosed, since it will be subject to
supplementary scrutiny by supervisors, thus enabling all market participants to take more
informed decisions.
Figure 2: Integration of disclosure requirements with supervisory reporting
Reporting compliance tool
235. The EBA plans to develop a tool, in particular for small and less complex institutions, to support
institutions’ compliance with the reporting requirements by helping them to understand which
templates are applicable based on various criteria (e.g. the regulatory regime, the prudential
approach, the group structure, small/large institution, risk/exposure thresholds and entry/exit
criteria). The tool will provide only indicative guidance on which parts of the reporting
framework are applicable to an institution and will have no binding force in law. The
development is planned to take place in 2020.
Changes to the reporting framework and implementation timelines
236. The EBA is conscious that both the implementation of the new reporting requirements and the
changes to reporting requirements implemented earlier involve costs for institutions as well as
authorities. Therefore, it aims to achieve stability in each reporting module by clustering change
needs. The EBA reporting framework is reviewed on an annual basis, module by module, to
assess change needs and define a timeline for implementing those changes. Reporting changes
are stemming from changes in the underlying regulations or changing supervisory needs, but
smaller technical amendments are also needed, for example to implement Q&As and rectify
clerical errors.
237. Against this backdrop, the EBA communicates its plans for framework releases by establishing a
tentative, forward-looking calendar of annual changes to the reporting framework, which was
published for the first time for versions 2.9 and 2.10 of the reporting framework. The EBA’s
website provides complete reporting frameworks, including legal texts, templates, instructions
and technical documentation for each framework release. The EBA also maintains a technical
framework in which all versions can be tracked and built up into an integrated, version-managed
system.
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238. The EBA considers it important that institutions and authorities alike have enough time to
implement new reporting requirements. The EBA’s target continues to be to provide a 12-month
implementation period from publication of the final draft ITS on the EBA’s website to the day
when the first reporting will take place. In some cases, this has not been possible in the past,
and it may not always be in the future, owing to the timelines of changes in the underlying
regulations or the cycle of annual exercises (supervisory benchmarking). CRR 2 introduces a
minimum implementation period of 6 months after the publication of the relevant technical
standard in the Official Journal, which the EBA will respect and reflect in its planning.
Validation rule management
239. The EBA has started work to improve management of validation rules. The EBA is running a long-
term project to overhaul the management of validation rules; however, it aims to launch
measures in the medium term to allow swifter corrective action in case of erroneous validation
rules. The EBA expects these measures to reduce resource needs and the need for manual
interventions for institutions and supervisory authorities alike.
6.3 Expected timeline for deliverables
Table 6: Timetable of mandates related to supervisory reporting
Mandate Reporting topic Original Deadline
Proposed Deadline
Expected 1st reference date
Art. 430 (7) CRR: EBA shall develop draft implementing technical standards to specify the uniform reporting formats and templates, the instructions and methodology on how to use those templates, the frequency and dates of reporting, the definitions and the IT solutions for the reporting referred to in paragraphs 1 to 4.
Art. 430 (1) (a) CRR Own funds
June 2021 June 2020 June 2021
Art. 430 (1) (a) CRR Credit risk
Art. 430 (1) (a) CRR Counterparty
credit risk
Art. 430 (1) (c) CRR Large exposures
Art. 430 (1) (d) CRR NSFR
Art. 430 (1) (e) CRR
IP losses
Art. 430 (1) (g) CRR Asset
encumbrance
Art. 47(a-c) CRR NPE backstop
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Art. 430 (1) (a) CRR Leverage ratio
June 2020 June 2020
Art. 430(2) CRR Leverage ratio
Art. 430 (9) CRR: EBA shall develop draft implementing technical standards to specify the formats and templates that institutions referred to in the first subparagraph shall use for the purposes set out therein.
Art. 430 (3, 4, 9) CRR
FINREP
June 2021 June 2020
Art. 430 (7) CRR: EBA shall develop draft implementing technical standards to specify the uniform reporting formats and templates, the instructions and methodology on how to use those templates, the frequency and dates of reporting, the definitions and the IT solutions for the reporting referred to in paragraphs 1 to 4.
Art. 430 (1) (b) CRR
TLAC
June 2020 June 2020 June 2021
Art.45(i) (5): EBA shall develop draft implementing technical standards to specify uniform reporting templates, instructions and methodology on how to use the templates, frequency and dates of reporting, definitions and IT solutions for the supervisory reporting referred to in paragraphs 1 and 2.
Art. 45(i) BRRD
MREL
Art.430 (b) (6): EBA shall develop draft implementing technical standards, to specify the uniform reporting templates, the instructions and methodology on how to use the templates, the frequency and dates of reporting, the definitions and the IT solutions for the reporting referred to in this Article
Art. 430(b)
Market risk (FRTB)
June 2020 April 2020 March 2021
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Art. 78 (8) CRD: EBA shall develop draft implementing technical standards to specify:
(a) the template, the definitions and the IT-solutions to be applied in the Union for the reporting referred to in paragraph 2;
(b) the benchmark portfolio or portfolios referred to in paragraph 1.
Art. 78 CRD Supervisory
benchmarking
- 2020-2021 2020-2022
Art.54(3) IFR: For the purposes of the reporting requirements laid down in this Article, EBA, in consultation with ESMA, shall develop draft implementing technical standards
Investment firms Expected
December 2020
December 2020
Tentative: September
2021
Art. 430(8) CRR: EBA shall assess the costs and benefits of the reporting requirements laid down in Commission Implementing Regulation (EU) No 680/201437 in accordance with this paragraph and report its findings to the Commission by 28 June 2020. That assessment shall be carried out in particular in relation to small and non-complex institutions.
Art. 430(8) CRR
Cost of compliance
June 2020 December 2020
-
Art 430(c) CRR: EBA shall prepare a report on feasibility regarding the development of a consistent and integrated system for collecting statistical data, resolution data and prudential data and report its findings to the Commission by 28 June 2020
Art. 430(c) CRR Integrated reporting
June 2020 June 2021 -
Art. 415 (3) (a)CRR: EBA shall develop draft implementing technical standards to specify which additional liquidity monitoring metrics as referred to in paragraph 3 shall apply to small and non-complex institutions.
Art. 415 (3) (a) CRR ALMM
June 2020 2021 2022
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Tel. +33 1 86 52 70 00 E-mail: [email protected]
https://eba.europa.eu/